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1999.
The issues remaining for decision are:
(1) Are petitioners entitled for 1999 to deductions with
respect to a sole proprietorship of petitioner Michael P. Hopkins
(Mr. Hopkins) in excess of the deductions allowed by respondent?
We hold that they are not.
(2) Should we sustain respondent’s determination to disal-
low a nonpassive loss that petitioners claimed in Schedule E of
their 1999 tax return as attributable to an S corporation owned
by Mr. Hopkins? We hold that we should.
(3) Are petitioners liable for 1999 for the accuracy-
related penalty under section 6662(a)? We hold that they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Dana Point, California, at the time
they filed the petition in this case.
From around 1965 until around 1979, Mr. Hopkins, who has a
bachelor of science degree in mechanical engineering, worked as
an engineer for Goodyear Tire and Rubber Company (Goodyear). In
1979, Mr. Hopkins left Goodyear and worked for a small tire
company in Indiana. In 1980, Mr. Hopkins began working in
Illinois and thereafter in California as a salesman for NRM
Corporation, a company that sold rubber and plastic extrusion
equipment to the tire industry and the plastics industry.
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