James Edward and Brenda Dianne Starkovich - Page 3

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          to be entered is not reviewable by any other court, and this                
          opinion should not be cited as authority.                                   
               Respondent determined for 2001 a deficiency in petitioners'            
          Federal income tax of $15,408 and an accuracy-related penalty of            
          $3,082 under section 6662(a).                                               
               The issues for decision are whether petitioners:  (1)                  
          Received unreported income during 2001; and (2) are liable for              
          the accuracy-related penalty under section 6662(a).                         
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  Petitioners                 
          resided in McKinney, Texas, at the time the petition was filed.             
               During 2001, James Edward Starkovich (petitioner) was a                
          residential and commercial painting contractor, and Brenda Dianne           
          Starkovich was a homemaker.  Petitioners timely filed their 2001            
          Federal income tax return.                                                  
               Attached to petitioners' return was a Schedule C, Profit or            
          Loss From Business, on which petitioner reported gross receipts             
          of $32,400 and expenses of $23,658 from his painting activities.            
               Petitioner worked at an apartment complex owned by Golden              
          Leaf, Inc. (Golden Leaf), performing repairs and maintenance,               
          painting apartments, and staining fences in 2001.  Golden Leaf              
          paid petitioner by check for his work at the apartments.  During            

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