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and this opinion shall not be treated as precedent for any other
case.
Respondent determined deficiencies in petitioner’s Federal
income tax of $7,799, $10,001, and $3,290 for 2002, 2003, and
2004, respectively. In addition, respondent determined that
petitioner was liable for accuracy-related penalties under section
6662 of $1,559.80 for 2002, $2,000.20 for 2003, and $658 for 2004.
The deficiencies arose as a consequence of respondent’s
disallowance of deductions petitioner claimed for losses in
connection with her partnership interest in the LB Tripp & Tripp
Group (the Tripp partnership). Embedded in the 2003 loss was a
$24,052 salary expense deduction for the value of cash and
equipment transferred to a third party in exchange for services
rendered to the partnership.
Respondent also determined a deficiency in the 2003 income
tax of petitioner’s former husband, Richard Powell Tripp (Mr.
Tripp), stemming from the disallowance of a deduction claimed for
a loss with respect to his interest in the Tripp partnership.2 Mr.
Tripp timely petitioned this Court, and his case at docket No.
5256-06S was consolidated with the instant case for trial. After
2The disallowed deduction for a loss in Mr. Tripp’s case was
in part attributable to the same $24,052 deduction for a salary
expense as in petitioner’s case.
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