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3. whether petitioner understated the net profits from his
consulting business by $24,016 in 1994, $7,037 in 1995, and
$13,094 in 1996;
4. (a) whether petitioner is a real estate dealer, and, if
so, whether he is entitled to deduct business losses of $121,966
reported in 1994, $72,546 reported in 1995, and $345,223 reported
in 1996, or alternatively
(b) if petitioner is not a real estate dealer, then
whether he is entitled to (i) deductions on Schedule A, Itemized
Deductions, greater than $25,665 in 1994, $45,066 in 1995, and
$8,545 in 1996, as allowed by respondent, and (ii) deductions for
rental expenses on Schedule E, Supplemental Income and Loss,
greater than $13,977, as allowed by respondent for 1994;
5. whether petitioner is entitled to deduct net operating
loss carryovers of $18,520 in 1994 and $36,389 in 1996;
6. whether petitioner is liable for self-employment tax of
$5,902 for 1994, $3,102 for 1995, and $3,626 for 1996;3 and
7. whether petitioner is liable for the accuracy-related
penalty under section 6662(a)4 for each of the years at issue.
3The parties agree that in computing petitioner’s Federal
income tax liability for each year petitioner may deduct one-half
of the self-employment tax.
4Unless otherwise noted, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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