-6-
on their returns for the relevant years in the deficiency
notices.7 Respondent determined that Mr. and Mrs. Hargrove are
not entitled to an exclusion under section 911 of $44,850 in 2000
and $31,861 in 2001, determined that the correct amount of tax is
$16,533 for 2000 and $12,620 for 2001, and determined that Mr.
and Mrs. Hargrove are also liable for the accuracy-related
penalty.8 Respondent determined that Mr. and Mrs. Kirkpatrick
are not entitled to an exclusion under section 119 of $6,606 in
2000 and $6,698 in 2001. Respondent determined that Mr. and Mrs.
Nakagawa are not entitled to an exclusion under section 119 of
$6,607 in 1999, $6,606 in 2000, and $6,698 in 2001 and that Mr.
and Mrs. Nakagawa are liable for the accuracy-related penalty.
Respondent has since conceded that Mr. and Mrs. Nakagawa are not
liable for the accuracy-related penalty. Respondent determined
that Mr. and Mrs. Anthony are not entitled to an exclusion under
section 119 of $7,056 in 2000 and $7,154 in 2001. Finally,
respondent determined that Mr. and Mrs. Breeding are not entitled
to exclusions under section 119 of $7,056 in 2000 and $7,154 in
2001, and their exclusions under section 912 of $34,285 in 2000
and $36,357 in 2001. Respondent determined that the correct
amount of tax Mr. and Mrs. Breeding owe is $35,467 for 2000 and
7None of petitioners’ returns was introduced as evidence in
any of these cases.
8In Docket No. 16441-04, Mr. and Mrs. Hargrove asserted in
the petition that they were entitled to deductions for housing
expenses under sec. 119 and met the requirements for exclusion of
certain income under sec. 912.
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