- 2 -
be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax for the taxable year 2000 of $6,826 and an accuracy-
related penalty under section 6662(a) of $1,365.
After petitioners’ concession,2 the issues for decision are:
(1) Whether petitioners are entitled under section 119 to
exclude from gross income the value of lodging furnished to
petitioner Ron L. Abeyta (Mr. Abeyta). We hold that they are
not.
(2) Whether petitioners are liable for self-employment tax
on the value of lodging furnished to Mr. Abeyta. We hold that
they are not.
(3) Whether petitioners are liable under section 6662(a)
for an accuracy-related penalty. We hold that they are not.
An adjustment to the amount of petitioners’ itemized
deductions is purely a computational matter, the resolution of
which is dependent on our disposition of the disputed issues.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
2 Petitioners concede that they are not entitled to claim a
cost-of-living allowance exclusion under sec. 912.
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