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$6,215. Respondent concedes that petitioner is not liable for
the addition to tax under section 6651(a)(2) or under section
6654.
The issues for decision are whether petitioner is entitled
to a deduction under section 166 for a bad debt loss in 1999;
whether petitioner is entitled to an interest expense deduction
under section 163; whether petitioner is liable for the addition
to tax for failure to file under section 6651(a)(1); and whether
a penalty should be awarded to the United States under section
6673 by reason of petitioner’s failure to exhaust his
administrative remedies.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Correspondence and communications between the parties are set
forth in respondent’s motion to compel production of documents
and motion under section 6673. Petitioner resided in New York,
New York, at the time that he filed his petition.
Petitioner was not in a trade or business during 1999 but
received income as a result of investments. In 1999, petitioner
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