Sylwester A. Slojewski - Page 3

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          return.  Petitioner concedes that he may not deduct the remaining           
          $1,635.00 of claimed deductions.                                            
               4.  Petitioner concedes that he may not deduct the remaining           
          $19,925.00 of Schedule C expenses that he claimed on his 2000 tax           
          return.  Those disallowed deductions are as follows:                        
                    (a) $750.00 of advertising expenses;                              
                    (b) $4,000.00 of commissions and fees expenses;                   
                    (c) $1,250.00 of insurance expenses;                              
                    (d) $8,000.00 of legal expenses;                                  
                    (e) $3,000.00 of office expenses;                                 
                    (f) $600.00 of repair expenses;                                   
                    (g) $525.00 of taxes and licenses expenses; and                   
                    (h) $1,800.00 of travel and entertainment expenses.               
                    5.  Respondent concedes that, as a result of                      
               respondent’s concession in paragraph 2, petitioner is                  
               not liable for an accuracy-related penalty under I.R.C.                
               � 6662(a) for the taxable year 2000.                                   
          The Court ordered the parties to submit a decision document by              
          January 18, 2005.                                                           
               On January 6, 2005, respondent mailed to petitioner’s                  
          counsel a proposed decision document.  On January 10, 2005,                 
          respondent received from petitioner’s counsel a letter dated                
          January 7, 2005, in which petitioner’s counsel stated that he               
          anticipated prompt approval by petitioner of the proposed                   
          decision document.                                                          
               On the next day, January 11, 2005, respondent received a               
          letter from petitioner’s counsel dated January 8, 2005, in which            
          petitioner’s counsel stated:                                                
                    I also have completed my review of your                           
               computation of the income tax liability that flows from                
               the settlement of this case.  I do not entirely agree                  
               with your computation.                                                 





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