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ered that the truck and the trailer that they had driven to Texas
were not large enough to transport all of that equipment back to
Alaska. Consequently, at a time not established by the record,
petitioners purchased another truck and another trailer to use in
transporting to Alaska the farm equipment that they had purchased
in Texas.
In the notice of deficiency issued to petitioners for 1992
and 1993 (notice), respondent determined, inter alia, to disallow
deductions for 1993 for certain of the total expenses claimed in
Schedule C because petitioners did not establish that Mr. Petty
was engaged in a trade or business during 1993, that such ex-
penses were paid or incurred during 1993, and that such expenses
were ordinary and necessary expenses within the meaning of
section 162(a). Respondent further determined, inter alia, that
petitioners are liable for 1993 for the addition to tax under
section 6651(a)(1) for their failure to file timely petitioners’
joint return.
OPINION
At trial, respondent conceded all determinations in the
notice relating to 1992 and 1993, except certain determinations
for 1993.3 After concessions, it is respondent’s position that
3In addition to respondent’s concessions of most of the
determinations in the notice, respondent conceded at trial that
petitioners are entitled for 1993 to deductions in Schedule F,
Profit or Loss from Farming, in excess of those claimed by them
(continued...)
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