George R. and Donelle C. Hawthorne - Page 18




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          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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