Dale I. Dirkes - Page 6




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          he is liable for an addition to tax pursuant to section                     
          6651(a)(1) of $3,498.50; and (6) whether he is liable for an                
          addition to tax pursuant to section 6654(a) of $671.13.                     
               For the purpose of this motion, respondent concedes the                
          capital gain adjustment of $60,628, and petitioner admits having            
          received wages of $37,323 from MCI for 1994.                                
               Based on decreased adjusted gross income resulting from                
          respondent’s concessions, respondent concedes that petitioner is            
          entitled to an exemption in the amount of $2,450.  This                     
          adjustment is not at issue.                                                 
               Respondent concedes that petitioner is entitled to a                   
          standard deduction of $3,800 based upon “single” filing status.             
          This adjustment is not at issue.                                            
               Respondent concedes that petitioner is not liable for                  
          additions to tax pursuant to sections 6651(a)(1) and 6654(a).               
                                   Conclusion                                         
               For the reasons stated herein, we find and hold that there             
          is no genuine issue as to any material fact remaining for                   
          litigation in this case and that a decision may be rendered as a            
          matter of law.                                                              













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