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2. Are petitioners entitled to deduct for 1996 claimed
rental expenses of $98,103.07? We hold that they are not.
3. Are petitioners entitled to deduct for 1992, 1993,
1994, 1995, and 1996 claimed legal, interest, and/or other
expenditures totaling $59,130.12, $64,014.86, $105,679.24,
$123,232.28, and $131,633, respectively? We hold that they are
not.
4. Are petitioners entitled to deduct for 1996 deprecia-
tion in excess of the amount conceded by respondent? We hold
that they are not.
5. Do petitioners have for each of the years at issue a
total amount of credits for withholding and estimated tax pay-
ments in excess of the total amount of such credits determined by
respondent for each such year? We hold that they do not.
6. Are petitioners liable for each of the years at issue
for the addition to tax under section 6651(a)(1) and for 1996 for
the addition to tax under section 6651(a)(2)? We hold that they
are.
7. Are petitioners liable for each of the years at issue
for the addition to tax under section 6654? We hold that they
are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Certain other facts are deemed admitted pursuant to Rule 90(c).
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