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(1) the correct amount of gross income for 1992 and 1993, and (2)
interest expense deductions for 1992 and 1993. Finally, the
parties stipulated each item of income and expense in connection
with Special O for 1991, 1992, and 1993, with the exception of
(1) travel expense deductions for 1991, 1992, and 1993; (2)
interest expense deductions for 1991, 1992, and 1993; (3) the
correct amount of gross income for 1992 and 1993; and (4) a
section 179 expense deduction for 1993. At trial, petitioner
conceded the interest expense deductions for 1991, 1992, and
1993, with respect to Special O and the interest expense
deductions of Special Occasions for 1992 and 1993.3
Section 61 defines gross income as all income from whatever
source derived. With respect to a partnership, each partner
shall take into account separately his or her distributive share
of the partnership's taxable income or loss. See secs.
3
Notices of deficiency were issued by respondent to each of
petitioner's sisters, making adjustments to income and deductions
that flowed through to them from the entities in which they were
involved with petitioner. Each of the sisters filed a petition
with this Court. Their cases, the years involved, and the
opinions of the Court are referenced as follows:
Johnny and Faye W. Oatis, docket No. 17068-96S, 1992 and
1993, T.C. Summary Opinion 1998-88
Barbara J. Wilson, docket No. 17067-96S, 1992 and 1993, T.C.
Summary Opinion 1998-99
Marian Wilson, docket No. 12687-97, 1991, 1992, and 1993,
T.C. Memo. 1999-141
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