-368-
otherwise final. See secs. 7481(a)(1), 7483.146 Consequently, we
need not consider this issue.
Issue X. Whether the Kanters Received Unreported Interest Income
During 1988 (STJ report at 136-137)
Respondent determined in the notice of deficiency issued to
the Kanters for 1988 that the Kanters failed to report interest
income they received during 1988. This adjustment was resolved
in petitioners’ favor, and the decision entered by the Court at
docket No. 26918-92 (taxable year 1988) on September 24, 2001,
was not appealed and is otherwise final. See secs. 7481(a)(1),
7483.147 Consequently, we need not consider this issue.
Issue XI. Whether the Kanters Are Entitled to Certain Deductions
They Claimed on Schedules A and C for 1986 to 1989
(STJ report at 137-144)
In notices of deficiency issued to the Kanters for 1986 to
1989, respondent disallowed deductions the Kanters claimed on
Schedules A and C of their tax returns for those years. These
adjustments were resolved in petitioners’ favor, and the
decisions entered by the Court at docket Nos. 24002-91 (taxable
year 1987), 26918-92 (taxable year 1988), and 25981-93 (taxable
year 1989) on September 24, 2001, were not appealed and are
otherwise final. See secs. 7481(a)(1), 7483.
146 Respondent does not challenge the ultimate conclusion in
the STJ report on this issue.
147 Respondent does not challenge the ultimate conclusion in
the STJ report on this issue.
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