Chad W. and Aliza Kold-Warren - Page 4

          related penalty under section 6662(a) in the amount of 20 percent           
          of the deficiency, or $1,182.60.                                            
               Petitioners’ alternative computation asks the Court to                 
          decide that the amount of the deficiency is $2,225.  Petitioners’           
          computation does not discuss the accuracy-related penalty under             
          section 6662(a).  Nevertheless, we note that the Court expressly            
          sustained respondent’s determination of the accuracy-related                
          penalty in its bench opinion, and petitioners’ liability for the            
          accuracy-related penalty under section 6662(a) is not in issue in           
          these proceedings under Rule 155.  The decision in this case will           
          include petitioners’ liability for an accuracy-related penalty in           
          the amount of 20 percent of the deficiency.                                 
               A summary of the deficiency computations of both parties is            
          appended hereto as Appendix.  There are six differences between             
          petitioners’ computation and respondent’s revised computation.              
          The attached summary highlights those six differences.  We                  
          address each of them below.                                                 
               Item No. 1:  Petitioners’ computation claims a capital loss            
          of $1,848, whereas respondent’s revised computation allows a                
          capital loss of $1,719, a difference of $129.  Paragraph 13 of              
          the Stipulation of Facts states that petitioners incurred a                 
          capital loss of $1,719 during 2002.  Accordingly, the capital               
          loss allowed in respondent’s revised computation is correct.                

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