Robert and Clara Satriana - Page 4




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          unreimbursed employee business expenses; (3) whether, for the               
          years 1998 and 1999, petitioners are entitled to itemized                   
          deductions for home mortgage interest in excess of amounts                  
          conceded by respondent; (4) whether, for the year 1998,                     
          petitioners are entitled to an itemized deduction for real estate           
          taxes in excess of an amount orally conceded by respondent at               
          trial; (5) whether petitioners are entitled to deductions for               
          expenses incurred by Mrs. Satriana during 1999 in the conduct of            
          a trade or business activity; and (6) whether petitioners are               
          liable for the accuracy-related penalties under section 6662(a).            
          In addition, the Court considers the applicability of section               
          6673(a) to the facts of this case.                                          
               Some of the facts were stipulated, and those facts, with the           
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioners'                
          legal residence was Bernalillo, New Mexico.                                 
               Petitioners were both employed during the years at issue.              
          Mr. Satriana was a building inspector for the City of Rio Rancho,           
          New Mexico, and Mrs. Satriana was administrator for a substance             
          abuse prevention program for Sandoval County, New Mexico.  In               
          addition, for the year 1999, Mrs. Satriana was engaged in a Mary            
          Kay Cosmetics business activity.                                            
               On their joint Federal income tax returns for the years at             
          issue, petitioners reported gross salary and wage income of                 





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