Tunji and Christina Mabinuori - Page 3

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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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