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The issues for decision are:3 (1) Whether petitioners are
entitled to deduct various business expenses in excess of the
amounts allowed by respondent; (2) whether petitioners failed to
include interest and dividends as income; (3) whether petitioners
may deduct interest payments in excess of the amounts allowed by
respondent; (4) whether petitioners are entitled to an investment
tax credit for 1993; and (5) whether petitioners are liable for
the accuracy-related penalty pursuant to section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the related exhibits are incorporated
herein by this reference. At the time of filing the petition in
this case, petitioners resided in Washington, D.C. Any
references to petitioner are to Howard L. Burris, Sr.
Petitioner received a degree in geology from West Point.
Before 1990, petitioner worked as a consultant to various
3 Respondent determined that petitioners failed to
include $1 of income in 1993 from Social Security. Respondent
disallowed deductions of $15,597 from Schedule E, Supplemental
Income and Loss, for 1991. Petitioners did not present evidence
as to these issues. As a result, petitioner is deemed to have
conceded these issues. See Rules 142(a), 149(b); Pearson v.
Commissioner, T.C. Memo. 2000-160.
The notices of deficiency contain adjustments to
petitioners’ itemized deductions, alternative minimum tax,
employment tax, and dependency exemption deductions. These are
computational adjustments which will be affected by the outcome
of the other issues to be decided, and we do not separately
address them.
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