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precedent for any other case. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a $10,048 deficiency in petitioners’
Federal income tax for 2002 and a $2,009.60 accuracy-related
penalty under section 6662(a).
The deficiency resulted from respondent’s disallowance of:
(1) $12,000 deducted as an other miscellaneous deduction for
“home winterization” on Schedule A, Itemized Deductions, and (2)
the following expenses claimed on Schedule E, Supplemental Income
and Loss, for rental Property B (identified as an “apartment
building” located at 8314 South Green Street):
Advertising $350
Auto and travel 4,500
Cleaning and maintenance 3,000
Repairs 12,000
Supplies 900
Utilities 3,000
Petitioners attached a Schedule E to their Federal income
tax return for 2002 showing three properties as follows: (1)
Property A, a “2-flat building” located at 8314 South Green
Street; (2) Property B, an “apartment building” located at 8314
South Green Street; and (3) Property C, an “apartment building”
located at 8314 South Green Street.
In the deficiency computation, respondent increased the
amount of the alternative minimum tax shown on the return and
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