MEMORANDUM OPINION
PARR, Judge:
Respondent determined a $156,139 deficiency in petitioner's 1992 Federal income tax and additions to tax under sections 6651(a)
After concessions, the issues for decision are: (1) Whether for 1992 petitioner is entitled to deduct 50 percent of the substantiated expenses incurred for certain rental real estate. This turns on...
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