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Respondent determined a $2,263 deficiency in petitioners’
Federal income tax for 2002 and a $453 accuracy-related penalty
under section 6662(a). After concessions by the parties,1 the
issues for decision are: (1) Whether petitioners’ gross income
includes $15 of wage income from Farmers Insurance Group
(Farmers); (2) whether petitioners’ gross income includes $3,845
of self-employment income from Metropolitan Property and Casualty
Insurance Company (MetLife); and (3) whether petitioners are
liable for an accuracy-related penalty under section 6662(a).
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the supplemental stipulation
of facts with attached exhibits are incorporated herein by this
reference. Petitioners Tunji Mabinuori (Mr. Mabinuori) and
Christina Mabinuori (Mrs. Mabinuori) are married and resided in
Springfield, Oregon, when their petition was filed. Unless
otherwise indicated, all references to petitioner are to Mr.
Mabinuori.
1. Petitioner’s Involvement With Farmers
1 Petitioners concede they received and failed to report a
$1,844 State income tax refund. Petitioners assert in the
petition that they are entitled to deductions for “business
mileage” that were not claimed on their 2002 joint Federal income
tax return; however, petitioners did not pursue this argument at
trial, and we therefore consider the argument abandoned. See
Nicklaus v. Commissioner, 117 T.C. 117, 120 n.4 (2001); Korchak
v. Commissioner, T.C. Memo. 2005-244 n.6. For convenience, we
address the parties’ additional concessions infra. Adjustments
not addressed herein are computational.
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