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Revenue Code, as amended, in effect for 1993. The Court agrees
with and adopts the opinion of the Special Trial Judge, which is
set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
CARLUZZO, Special Trial Judge: Respondent determined a
deficiency of $8,922 in petitioner’s 1993 Federal income tax and
a section 6662 penalty of $1,784.
The issues for decision are: (1) Whether petitioner is
entitled to any of the deductions claimed on a Schedule C, Profit
or Loss From Business, included with his 1993 Federal income tax
return; (2) whether petitioner is entitled to a credit for what
is identified as a “carry forward loss” on his 1993 return; (3)
whether petitioner is entitled to exclude from income or defer
the gain realized from the sale of his residence; and (4) whether
any underpayment of tax required to be shown on petitioner’s 1993
return is due to negligence.
Background
Some of the facts have been stipulated and are so found.
At the time that the petition was filed, petitioner resided in
Columbus, Ohio.
In 1992, petitioner was convicted of filing a false 1984
Federal income tax return. As a result, among other sanctions,
he was ordered to “pay a fine to the United States in the amount
of ten thousand ($10,000) dollars”. As best as can be determined
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