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material fact, and factual inferences will be made in a manner
most favorable to the party opposing summary judgment. See
Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985).
As previously discussed, the issues framed by the pleadings
in this case are: (1) Whether petitioner failed to report
capital gain of $137,835; (2) whether petitioner failed to report
interest income of $13; (3) whether petitioner should have
reported as income a $227 State tax refund; (4) whether
petitioner failed to report wages of $103,582; (5) whether
petitioner is liable for an addition to tax pursuant to section
6651(a)(1) of $13,143; and (6) whether petitioner is liable for
an addition to tax pursuant to section 6654(a) of $2,115.63.
As we have stated, supra, respondent for the purpose of his
motion, concedes the capital gain adjustment of $137,835.
Petitioner admits having received interest income of $13
(petition par. 5.A.).
Petitioner admits having received a (state) tax refund of
$227 (petition par. 5.A.).
Petitioner admits having received wages of $103,636.86
(petition par. 5.A.).3
3 Included in petitioner’s income figure of $103,636.86
is $54 for sports officiating. The $54 is not included in
respondent’s “wages” adjustment of $103,582, and respondent does
not assert a claim for the amount.
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