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Petitioners’ Reliance on Facts Found in Barmes v.
Commissioner, T.C. Memo. 2000-254 ....... 73
Respondent’s Determination Regarding Petitioners’
Claimed Schedule C Gross Receipts .......... 74
Respondent’s Determination Regarding Petitioners’
Claimed Depreciation Deductions ........... 79
Respondent’s Determination Regarding the Accuracy-Related
Penalty Under Section 6662(a) ............ 81
Penalty Under Section 6673(a)(1) ............. 84
CHIECHI, Judge: Respondent determined a deficiency in, and
an accuracy-related penalty under section 6662(a)1 on, petition-
ers’ Federal income tax for 1995 in the amounts of $315,478 and
$63,095.60, respectively.
The issues remaining for decision2 are:
(1) Did petitioners have unreported taxable income for 1995
in the amount of $890,719? We hold that they did.
(2) Are petitioners entitled to the depreciation deductions
that they claimed for 1995 with respect to two automobiles? We
hold that they are not.
(3) Are petitioners liable for the accuracy-related penalty
under section 6662(a)? We hold that they are.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the year at issue.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
2Certain computational issues also remain for 1995, resolu-
tion of which flows automatically from our resolution of the
determinations in the notice that we address herein.
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Last modified: May 25, 2011