Sarah A. Bland-Barclay and Francis Barclay - Page 2

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               After a concession by petitioners,1 the remaining issues in            
          this case are:  (1) Whether wage income received by petitioners             
          in the amount of $87,118.92 in 1996, except for wages of $432.48            
          from Defense Finance and Accounting Service, an agency of the               
          Federal Government, is nontaxable, thereby resulting in an                  
          overpayment of income tax for the taxable year; (2) whether                 
          petitioners are entitled to Schedule A, Itemized Deductions, in             
          excess of the amounts which respondent allowed; (3) whether                 
          petitioners are entitled to various Schedule C, Profit and Loss             
          From Business, deductions beyond that which respondent allowed;             
          and (4) whether petitioners are liable for an accuracy-related              
          penalty under section 6662(a).                                              
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          was filed, Sarah A. Bland-Barclay resided in Baltimore,                     

          1    Petitioners conceded in the Stipulation of Facts that                  
          petitioner Sarah A. Barclay received a Form W-2, Wage and Tax               
          Statement for 1996, from Olsten Home Healthcare, Inc. (Olsten),             
          reporting that she received $1,268.81 of wage income.  We note              
          that in the notice of deficiency respondent determined that                 
          petitioners failed to include wage income of $1,267.  The record            
          does not explain the $1.81 discrepancy between the amount on the            
          Olsten Form W-2 and the notice of deficiency.  We accept                    
          respondent’s assertion that the amount in dispute is $1,267 as              
          stipulated by petitioners and determined in the notice of                   

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