John Mosier and Sarah Spain - Page 3




                                        - 2 -                                         
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
               Respondent determined deficiencies in petitioners’ Federal             
          income taxes of $1,756, $8,480, and $6,059 for the taxable years            
          1993, 1994, and 1995, and an addition to tax under section                  
          6651(a)(1) in the amount of $287 for taxable year 1995.                     
               The issue for decision is whether petitioners have                     
          substantiated various business expense deductions and itemized              
          deductions.1                                                                
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Jefferson, Louisiana, on the date the petition was filed in this            
          case.                                                                       
               The following concessions were made by the parties in the              
          Stipulation of Facts.  Respondent concedes the addition to tax              
          under section 6651(a)(1).  Petitioners concede that (1) they are            
          not entitled to deductions in 1994 for bad debt expense and legal           
          expense of $22,950 and $4,338, respectively, and (2) a State                





          1Adjustments in the notice of deficiency to medical expense                 
          deductions in 1994 and 1995, and the application of the floor on            
          miscellaneous itemized deductions in each of the years in issue,            
          are computational and will be resolved by the Court’s holding on            
          the issue in this case.                                                     




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