Clair and Judith Worthington - Page 2




                                        - 2 -                                         
          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               Respondent determined deficiencies in petitioners' 1994 and            
          1995 Federal income taxes in the amounts of $990 and $473,                  
          respectively, and accuracy-related penalties under section                  
          6662(a) for the years 1994 and 1995 in the amounts of $198 and              
          $110, respectively.                                                         
               After concession by both parties,1 the issues for decision             
          are:  (1) Whether petitioners are entitled to claimed bad debt              
          deductions under section 166 for 1994 and 1995; (2) whether                 
          petitioners failed to include interest income in their 1994                 
          Federal income tax return; and (3) whether petitioners are liable           
          for the accuracy-related penalties under section 6662.                      
               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.  Petitioners resided in              
          Baldwin, Michigan, when the petition in this case was filed.                
          All references to petitioner are to Clair Worthington.                      


          1    Respondent conceded:  (1) Petitioners are entitled to a                
          legal and professional expense deduction for the year 1994 in the           
          amount of $4,500; (2) petitioners did not receive taxable refund            
          income in the year 1995 in the amount of $828; (3) petitioners              
          are entitled to a tax preparation expense deduction for the year            
          1994 in the amount of $180, with $90 being allocated to Schedule            
          A and $90 being allocated to Schedule C.  Petitioners conceded              
          that they are not entitled to the entire claimed legal and                  
          professional expense deduction of $6,080 for the year 1995 but              
          are only entitled to such a deduction for that year in the amount           
          of $2,080.                                                                  




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