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Court agrees with and adopts the opinion of the Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
DEAN, Special Trial Judge: Respondent determined a
deficiency in and additions to petitioner's Federal income tax
for calendar year 1999 as follows:
Additions to Tax1
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1999 $42,717 $7,534 $2,679 $1,559
1 The following figures are rounded to the nearest dollar.1
After concessions,2 the issues for decision are: (1)
Whether respondent raised new matters and bears the burden of
proof under Rule 142(a) regarding petitioner’s entitlement to
certain deductions; (2) whether petitioner is entitled to a
deduction for capital loss carryforwards; (3) whether petitioner
is entitled to deduct rental expenses in excess of those allowed
by respondent; (4) whether petitioner is required to include in
income a distribution from a Roth IRA; and (5) whether petitioner
is liable for the addition to tax for failure to file a tax
return under section 6651(a)(1).
2Respondent concedes that petitioner is not liable for the
addition to tax for failure to pay tax under sec. 6651(a)(2) and
the addition to tax for failure to make estimated tax payments
under sec. 6654.
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