Marian and Maria Juskuv - Page 2




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                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               GOLDBERG, Special Trial Judge:  Respondent determined a                
          deficiency for 1995 in the amount of $3,914 and additions to tax            
          pursuant to sections 6651(a)(1) and 6654 of $2,171 and $364,                
          respectively.                                                               
               After concessions, the issues for decision are:  (1) Whether           
          petitioners are entitled to deduct claimed Schedule C expenses              
          and Schedule E losses; (2) whether petitioners are entitled to              
          claim a $3,000 short-term capital loss on Schedule D for 1995;              
          (3) whether petitioners are liable for an addition to tax                   
          pursuant to section 6651(a)(1); and (4) whether petitioners are             
          liable for an addition to tax pursuant to section 6654.                     
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time that the                
          petition was filed, petitioners resided in Canton, Massachusetts.           
          References to petitioner are to Marian Juskuv.                              
                                     Background                                       
               Petitioners emigrated from Slovakia to the United States in            
          1980.  While living in Slovakia, petitioner earned a college                
          degree in electronics from a technical college in Kosice.  In               
          1995, petitioner worked as an electronics technician in Boston              
          for Teradyne, Inc.  Maria Juskuv was also employed during 1995              








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