-2-
qualifies for relief under sec. 6015(b), (c), and (f),
I.R.C., but now contends that she qualifies for relief
only under sec. 6015(f), I.R.C. R contends that the
Tax Court lacks jurisdiction to decide W’s claim under
sec. 6015(f), I.R.C.
Held: All transcription-related self-employment
income is allocated to W under secs. 6017 and
1402(a)(5)(A), I.R.C.
Held, further, Ps’ rental cabin expenses are not
deductible because they are preoperational startup
expenses. See sec. 195, I.R.C.
Held, further, H does not qualify for relief under
sec. 6015(b), I.R.C., but he qualifies for limitation
of liability under sec. 6015(c), I.R.C., to the extent
stated herein.
Held, further, We have jurisdiction to review
whether relief is available under sec. 6015(f), I.R.C.
Fredie Lynn Charlton, pro se.
Sarah K. Hawthorne, pro se.
Deborah H. Delgado, Carl D. Inskeep, and Lewis J. Hubbard,
for respondent.
COLVIN, Judge: Respondent determined that, for 1994,
petitioners were liable for a $15,192 deficiency in income tax
and a $1,731 accuracy-related penalty under section 6662(a).
Following concessions,1 the issues for decision are:
1. Whether all of petitioners’ self-employment income from
1 Respondent concedes that petitioners are not liable for
the accuracy-related penalty under sec. 6662 for 1994. Both
petitioners and respondent agree that petitioners understated
Medi-Task gross receipts for 1994 by $22,601 on their 1994
return.
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