Adrian D. Troutman, Jr. - Page 2

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          of $4,454 for 1999.  After concessions,2 the issues for decision            
          are:  (1) Whether Adrian D. Troutman, Jr. (petitioner), is                  
          entitled to a deduction pursuant to section 162(a)(1) for alleged           
          additional compensation paid to his employee;3 and (2) whether              
          petitioner is entitled to a deduction for costs associated with             
          the construction of a logging road on his property.                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Winlock, Washington.                        
               During 1999, petitioner operated three sole proprietorships:           
          T-Foil Enterprises, A & J Insulation Contractors (Washington),              
          and A & J Insulation Contractors (Oregon).  T-Foil Enterprises              
          manufactured insulation, while A & J Insulation Contractors                 
          installed the insulation manufactured by T-Foil Enterprises.  The           
          insulation manufactured by T-Foil Enterprises was also sold to              
          third parties.                                                              




               2  Respondent has conceded all issues identified in the                
          notice of deficiency for 1999 and allowed a previously unclaimed            
          deduction for a charitable contribution of $6,405 for 1999.                 
               3  This issue was not included in the statutory notice of              
          deficiency or in the petition.  We find that the issue was tried            
          by consent pursuant to Rule 41(b)(1), and we consider it to be              
          before the Court.                                                           




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