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subsequent section references are to the Internal Revenue Code in
effect for the years in issue.
Respondent determined deficiencies in petitioner’s 1996 and
1997 Federal income taxes of $3,704 and $1,294, respectively, and
additions to tax under section 6651(a) of $926 and $323.50,
respectively. After concessions by petitioner of additional
amounts of income, the issues we must decide are whether
petitioner is entitled to any deductions in addition to those
allowed by respondent and whether petitioner is liable for the
additions to tax under section 6651(a).
Some of the facts have been stipulated and are so found.
Petitioner resided in Portland, Oregon, at the time he filed his
petition.
During the taxable years 1996 and 1997, petitioner was in
the real estate rental and/or investment business. At the end of
1997, a tax consultant prepared petitioner’s joint 1996 Federal
income tax return based on a spread sheet of rental income and
expenses and some other papers which were provided to her by
petitioner. At the end of 1998, the tax consultant also prepared
petitioner’s joint 1997 Federal income tax return based on
information petitioner provided to her. Each year, the tax
consultant provided petitioner with a copy of these returns.
Neither petitioner nor his wife ever signed these returns, and
they did not file these returns.
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