- 18 -
we find that petitioners did not prove that during the years at
issue Mr. Hawthorne was holding those properties for the produc-
tion of income. We further find that, except for the real estate
taxes conceded by respondent, see supra note 6, they are not
entitled for 1993 and 1994 to deduct as Schedule A deductions the
expenses that they claimed in Schedules C of their returns for
those years.8
To reflect the foregoing and the concessions of the parties,
Decisions will be entered
under Rule 155.
8 In so holding, we reject petitioners' contention that they
should be allowed to deduct as Schedule A deductions the Schedule
C expenses that respondent disallowed for 1993 and 1994 because
in the notice for 1992 respondent allowed petitioners to deduct
as Schedule A deductions the Schedule C expenses that respondent
disallowed for that year. Respondent's determination for 1992
does not bind this Court for 1993 and 1994.
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