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(6) whether petitioners properly deducted charitable
contributions and State and local taxes on Schedule A for 2000;
(7) whether petitioners properly claimed a dependency
exemption for a child for 2000; and
(8) whether petitioners are liable for additions to tax
under section 6651(a) for 1999 and 2000.3
Background
Petitioners were married during 1999 and 2000. Petitioners
resided in Detroit, Texas, when their petitions in these cases
were filed. Unless otherwise indicated, petitioner refers to A.
Wayne Doudney.4
On July 27, 2002, petitioners mailed Forms 1040X, Amended
U.S. Individual Income Tax Returns, for 1999 and 2000 to
respondent, who received them on July 29, 2002.5 After
petitioners mailed the amended returns, respondent requested
3Respondent also determined self-employment adjustments of
$306 and $4,137 for 1999 and 2000, respectively. The adjustments
are computational and turn on our resolution of the issue of
deductibility of the Schedules C, Profit or Loss From Business,
and F, Profit or Loss From Farming, expenses. Petitioners did
not separately challenge the adjustments, and we do not further
discuss them.
4Mr. Doudney attended the trial alone, but he stated on the
record that Mrs. Doudney authorized him to speak on her behalf
during the trial in these cases.
5There is no evidence in the record to show whether
petitioners filed original Forms 1040, U.S. Individual Income Tax
Returns, for the years in issue and, if so, when.
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