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determined in the alternative that petitioners are liable for the
accuracy-related penalty for negligence under section 6662 for
each year.
Petitioner1 and Donald J. Trisch (Trisch) formed a
partnership called Diversified Resources and Development (DRD) in
the early 1980's to own rental property. After concessions, the
issues for decision are:
1. Whether petitioner and Trisch continued to be partners
in DRD during the years in issue (1989-93). We hold that they
did.
2. Whether certain engineering income that Trisch earned
during the years in issue was income of the DRD partnership. We
hold that it was not. Thus, petitioners are not liable for tax
on that income.
3. Whether certain income and losses from real estate
rental property owned by DRD were partnership income and losses.
We hold that they were.
4. Whether tax years 1992 and 1993 should be dismissed
from this case. We hold that they should not.
5. Whether petitioners are liable for the accuracy-related
penalty under section 6662 for each year. We hold that they are
not.
1 References to petitioner are to Edward D. Lang.
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