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(3) whether petitioner’s filing status was single or married
filing separate in 1992;
(4) whether petitioner is entitled to only the standard
deduction or, instead, to itemized deductions, in 1990;
(5) whether petitioner is liable for the section 6651(a)(1)
addition to tax for failure timely to file income tax returns for
each of the 6 years at issue; and
(6) whether petitioner is liable for the section 6654
addition to tax for failure to pay estimated tax for each of the
6 years involved.
Additional adjustments to petitioner’s self-employment taxes
and deduction for self-employment taxes are computational in
nature and will be resolved by our holdings on the foregoing
issues.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
To facilitate disposition of the foregoing issues, we shall
first make general findings of fact and then combine our findings
and opinion with respect to each issue.
I. General Findings of Fact
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
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