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    3-

3.

whether

p

etitioner understated the net profits from his

consulting busines

s by $24,016 in 1994, $7,037 in 1995, and

$13,094 in 1996;

whether he is enti

tled to (i) deductions

on Schedule A, Itemized

Deductions, greate

r than $25,665 in 1994

, $45,066 in 1995, and

$8,545 in 1996, as

allowed by respondent

, and (ii) deductions for

rental expenses on

Schedule E, Supplemen

tal Income and Loss,

greater than $13,9

77, as allowed by resp

ondent for 1994;

er petitioner is a rea

l estate dealer, and, if

entitled to deduct bus

iness losses of $121,966

$72,546 reported in 19

95, and $345,223 reported

atively

titioner is not a real

estate dealer, then

wheth

so, whether he is

reported in 1994,

in 1996, or altern

pe

5.

whether

p

etitioner is entitled

to deduct net operating

loss carryovers of

$18,520 in 1994 and $

36,389 in 1996;

6.

whether

p

etitioner is liable fo

r self-employment tax of

$5,902 for 1994, $

3,102 for 1995, and $3

,626 for 1996;3 and

4.

(a)

(b)

if

7.

whether

p

etitioner is liable fo

r the accuracy-related

penalty under sect

ion

6662(a)

4

for

each

of the years at issue.

3The parties agree that in computing petitioner’s Federal income tax liability for each year petitioner may deduct one-half of the self-employment tax.

4Unless otherwise noted, 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.

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