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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.
In separate notices of deficiency, respondent determined
that petitioners are liable for the following deficiencies in
Federal income taxes, additions to tax, and penalty:
Docket No. 4479-00S Ronald and Nancy Sweet
Additions to Tax Penalty
Year Deficiency Sec. 6651(a) Sec. 6653(a) Sec. 6662(a)
1988 $1,137 $284 $89 --
1989 6,635 1,829 -- --
1993 1,587 -- -- $317
Docket No. 4480-00S Ronald T. Sweet
Addition to Tax
Year Deficiency Sec. 6651(a)
1990 $17,986 $4,497
1991 10,472 2,618
1992 12,722 3,181
After concessions by respondent,1 the issues for decision
are: (1) Whether petitioners are entitled to deduct certain
Schedule C expenses;2 (2) whether petitioners are liable for
1 Respondent concedes for the tax year 1993, that
petitioners in docket No. 4479-00S have substantiated Schedule C,
Profit or Loss From Business, cost of goods sold of $1,640, and
repairs expense deduction of $2,994, and are not liable for the
accuracy-related penalty under sec. 6662(a).
2 Petitioners reported as cost of goods sold for tax
years 1989, 1990, 1991, and 1993, amounts purportedly paid to
various subcontractors or workers. For purposes of this opinion,
(continued...)
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