Patrick F. Philippi - Page 2

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               (1)  Is petitioner entitled to deduct for 2000 claimed                 
          Schedule A expenses in excess of those allowed by respondent?  We           
          hold that he is not.                                                        
               (2) Is petitioner entitled to deduct for 1999 and 2000                 
          claimed Schedule C expenses?  We hold that he is not.                       
               (3) Is petitioner entitled to deduct for 1999 or 2000 a                
          claimed rental loss?  We hold that he is not.                               
                                  FINDINGS OF FACT                                    
               Many of the facts have been stipulated and are so found.               
               Petitioner resided in St. Paul, Minnesota, at the time he              
          filed the petition in this case.                                            
               During 1999 and 2000, petitioner worked as a carpenter, for            
          which he was paid hourly wages.  During those years, when peti-             
          tioner was not working as a carpenter for hourly wages, he was              
          making improvements to his personal residence, which included               
          building cabinets, installing trim, and making headpieces for the           
          doors.                                                                      


               1(...continued)                                                        
          below, there are other questions relating to certain determina-             
          tions in the notice of deficiency (notice) that are computational           
          in that their resolution flows automatically from our resolution            
          of the remaining issues that we address herein, from the parties’           
          stipulation of facts, and from respondent’s concessions with                
          respect to certain determinations in the notice.  Although                  
          petitioner claimed at trial that respondent determined that he              
          has unreported income for 2000, the notice did not make any such            
          determination.  We conclude that there is no issue in the instant           
          case relating to unreported income for petitioner’s taxable year            
          2000.                                                                       





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