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indicated, subsequent section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies of $4,123 and $13,379 in
petitioner’s 2002 and 2003 Federal income taxes, respectively.
With respect to petitioner’s 2002 taxable year, the issues for
decision are whether petitioner is entitled to the following:
(1) $6,000 in dependency exemption deductions; (2) a $3,800
deduction for alimony; and (3) a $6,905 casualty and theft loss
deduction. With respect to petitioner’s 2003 taxable year, the
issues for decision are whether petitioner is: (1) Entitled to
claim a $71,200 loss; and (2) liable for a $2,675.80 accuracy-
related penalty under section 6662(a).1
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petitions
were filed, petitioner resided in Flushing, New York.
Petitioner timely filed his 2002 and 2003 Federal income tax
returns. On his 2002 tax return, petitioner claimed personal
exemption deductions for his two sons who were ages 23 and 25 and
full-time students attending European schools. Petitioner also
1 Respondent conceded that petitioner was entitled to a
$1,900 moving expense deduction for 2002 and that he did not
receive $2,887 as nonemployee compensation in 2003.
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