Douglas L. Hadsell - Page 2




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          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.                                               
               Respondent determined deficiencies in petitioner’s Federal                
          income taxes and additions to tax as follows:                                  
                                         Additions to Tax                                
          Year      Deficiency           Sec. 6651(a)(1)      Sec. 6654                  
          1988      $2,162               $  526.00            $133.98                    
          1989      4,238                1,059.50             286.43                     
          1990      3,786                946.50               249.05                     

               After concessions by the parties,1 the issues for decision                
          are:  (1) Whether petitioner is entitled to the filing status of               
          married filing jointly for the purposes of determining the amount              
          of any liability for the 1990 taxable year; (2) whether                        
          petitioner is entitled to deductions for expenses incurred while               
          working as a deckhand on a commercial fishing boat; (3) whether                
          petitioner is entitled to deductions related to rental real                    
          property; (4) whether petitioner is entitled to casualty losses                



               1    Petitioner concedes that he received unemployment                    
          compensation, wages, and compensation as an independent                        
          contractor in at least the amounts determined by respondent.  We               
          therefore deem the gross income and self-employment tax issues to              
          be conceded by petitioner for the years at issue.                              
               Respondent concedes that there was a mathematical error in                
          the original determination as set forth in the notice of                       
          deficiency for the 1990 taxable year because petitioner was not                
          given credit equal to one-half of the self-employment tax he owed              
          for 1990.  Accordingly, the deficiency for 1990 should be reduced              
          by $127, with corresponding reductions in the secs. 6651 and 6654              
          additions to tax.                                                              





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