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petitioner may deduct amounts for 1994 greater than those allowed
by respondent and whether petitioner is liable for the additions
to tax set forth above. We hold that petitioner may not deduct
any greater amount and that he is liable for the additions to
tax. Section references are to the Internal Revenue Code in
effect for the subject years. Rule references are to the Tax
Court Rules of Practice and Procedure. Dollar amounts are
rounded to the nearest dollar.
FINDINGS OF FACT
Some facts have been stipulated. The stipulated facts and
the exhibit submitted therewith are incorporated herein by this
reference. Petitioner was self-employed during 1994 as a
computer engineer. He resided in Madison Heights, Michigan, when
he petitioned the Court.
Petitioner did not timely file a 1994 Federal income tax
return. Respondent determined petitioner's income tax liability
for 1994 and issued to him a notice of deficiency reflecting that
determination. Respondent later adjusted that determination to
take into account deductions raised and substantiated by
petitioner after the issuance of the notice of deficiency.
Petitioner asserts that, in addition to the deductions allowed by
respondent, he may deduct certain other amounts as business
expenses. Petitioner paid $3,600 to a personal acquaintance
(Elizabeth Helmboldt), $10,000 to his sister (Ruth Eileen
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