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are as follows:
(1) Whether each petitioner omitted from gross income
his or her respective community property law one-half
interest in the spouse’s earnings.
(2) Whether petitioners had unreported Schedule C gross
receipts for the years in issue, and, if so, then in what
amounts.
(3)(a) Whether petitioners are liable for the civil
fraud additions to tax under section 6663, or (b) in the
alternative, if petitioners’ underpayments (if any) are not
due to fraud, then whether petitioners are liable for the
negligence additions to tax under section 6662(a).
2(...continued)
shows gross receipts of $82,721--petitioners acknowledge 1995
plumbing business gross receipts of $88,502.
On brief, respondent indicates that respondent’s concessions
have the effect of reducing the original deficiency notice
determination by more than one-third as to Michael and by more
than half as to Sandra. Further concessions were made in the
course of certain postbrief proceedings. Infra note 24.
Computations will be required under Rule 155.
Unless indicated otherwise, all Rule references are to the
Tax Court Rules of Practice and Procedure.
3 The following adjustments are computational: (1) The
deduction for exemptions, (2) the child care credit, and (3) the
computation of both Michael’s self-employment tax liability and
self-employment tax deduction; their resolution depends on our
determination of the issues for decision.
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