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Respondent determined a deficiency of $2,019 and an addition
to tax of $504.75 pursuant to section 6651(a) in petitioner’s
Federal income tax for the taxable year 1995.
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner lived in Long Beach, California.
In the notice of deficiency, respondent determined that
petitioner: (1) Was not entitled to a claimed $23,039 net
operating loss (NOL) deduction; (2) was not entitled to deduct a
total of $2,990 of subcontractor expense claimed on four separate
Schedules C, Profit or Loss From Business; (3) was entitled to a
$40 deduction in arriving at adjusted gross income for one-half
of the increased self-employment tax resulting from the
disallowed Schedules C expenses; and (4) was subject to an
addition to tax pursuant to section 6651(a) for failure to file
his 1995 tax return by the prescribed due date.
Petitioner filed his petition with this Court requesting a
redetermination of the 1995 and 1987 tax years. Respondent
subsequently filed a Motion to Dismiss for Lack of Jurisdiction
and Strike as to the Taxable Year 1987. By order, on August 6,
2001, this Court granted respondent’s motion dismissing the 1987
taxable year for lack of jurisdiction because no notice of
deficiency was issued for that taxable year. However, the order
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