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deductions in issue.
Held, further, to meet his burden of production
pursuant to sec. 7491(c), I.R.C., as amended, R must
come forward with sufficient evidence indicating that
it is appropriate to impose a penalty, addition to tax,
or additional amount.
Held, further, R met his burden of production with
regard to the addition to tax and accuracy-related
penalty.
Earl G. Higbee and Lesley A. Higbee, pro sese.
Erin K. Huss, for respondent.
OPINION
VASQUEZ, Judge: Respondent determined the following
deficiencies in, addition to, and accuracy-related penalty on
petitioners’ 1996 and 1997 Federal income taxes:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1996 $10,796 $2,669 –-
1997 12,443 -- $2,488.60
Unless otherwise stated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, we must decide whether petitioners are
entitled to the following deductions: (1) $1,328 for a casualty
loss, (2) $6,937.20 for charitable contributions, (3) $6,468.09
for unreimbursed employee expenses, (4) certain amounts paid on
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