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David rendered on behalf of NLP and Scooper’s. See sec. 61(a);
James v. United States, supra. Accordingly, respondent’s
determinations are sustained.
E. Interest Income
Respondent determined that petitioners failed to report
interest income relating to 1986, 1987, 1988, 1989, 1991, and
1992. We sustain respondent’s determinations relating to David’s
accounts (i.e., interest earned in 1986, 1987, 1988, 1989, 1991,
and 1992), and Deborah’s accounts (i.e., interest earned in
1992).
III. Petitioners’ Claimed Loss Deductions
There is no evidence to support petitioners’ claimed 1987,
1988, 1989, and 1992 net operating loss deductions or 1992 rental
loss deduction. See sec. 6001; sec. 1.6001-1(a), Income Tax
Regs. Accordingly, respondent’s determinations are sustained.
IV. Self-Employment Income
Respondent determined that petitioners were liable, pursuant
to section 1401, for tax on self-employment income relating to
all the years in issue. We hold that, consistent with our
findings, petitioners are liable for self-employment tax relating
to income from NLP, Scooper’s, and David’s property management
activities relating to 1991 and 1992. See sec. 1402(a) and (b).
V. Additions to Tax and Penalties
Respondent determined additions to tax pursuant to sections
6651(a)(1), 6654(a), and 6661. Section 6651(a)(1) provides an
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