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1993 1994 1995
Michael and Angela Haas
Deficiency $34,416 -- –-
Sec. 6662(a) Accuracy-
Related Penalty 6,883 -- --
Haas & Associates
Accountancy Corp.
Deficiency -- $10,833 $7,457
Sec. 6662(a) Accuracy-
Related Penalty -- 2,167 1,491
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision involve claimed ordinary deductions
relating to a covenant not to compete and to consulting services,
a claimed exclusion from income of $151,000 relating to receipt
of shares of stock in an accounting firm, and the accuracy-
related penalties. All references to Haas are to petitioner
Michael Haas.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
When the petitions were filed, petitioners Michael and
Angela Haas resided in Novato, California, and the principal
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