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As previously stated, petitioners had borrowed $10,200 that
was deposited in an account held for them by petitioner’s mother.
That amount is not income to petitioners. On this record we find
there were no other nonincome items to reduce the remaining
$9,440. Consequently, we find that petitioners had unreported
additional income of $9,440 under the bank deposits method.
We agree with respondent that this additional $9,440 is
subject to self-employment tax under section 1401, and
petitioners are entitled to a corresponding 50-percent deduction
under section 164(f).
5. Claimed Casualty Loss
Respondent contends that petitioners are not entitled to a
casualty loss of $15,800 for the seizure and destruction of the
guns held for their alleged firearms business. Petitioners
claimed this loss on their amended return filed on April 16,
1999. No evidence was presented regarding this issue.
Accordingly, we deem petitioners to have abandoned it. Calcutt
v. Commissioner, 84 T.C. 716, 721-722 (1985); German v.
Commissioner, T.C. Memo. 1993-59, affd. without published opinion
46 F.3d 1141 (9th Cir. 1995). We hold that petitioners are not
entitled to a casualty loss.
6. Addition to Tax for Failure To File Timely Returns
Section 6651(a)(1) imposes an addition to tax for failure to
file a Federal income tax return by its due date, determined with
regard to any extension of time for filing previously granted.
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