Edward C. Tietig - Page 50

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               Petitioner concedes that he is liable for the addition to              
          tax pursuant to section 6651(a)(1) relating to 1990 and 1993, if            
          there is any tax due for those years before the application of              
          any net operating losses from other years.                                  
               Respondent concedes that petitioner is entitled to an                  
          itemized deduction for investment interest of $26,750 in 1991,              
          $20,309 in 1992, and $10,022 in 1993.  Respondent also concedes             
          that a $54,229.76 payment by Eureka Field Nursery to Mark Tietig            
          in 1991 was not a distribution to petitioner, that it does not              
          reduce petitioner’s basis in Eureka Field Nursery stock, and that           
          it does not reduce the loans owed petitioner by Eureka Field                
          Nursery.                                                                    

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