MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency in petitioners' income tax of $10,722 for 1992 and an addition to tax under section 6651(a)(1) of $2,658.25.
In 1992, petitioner Howard Howe (hereinafter "petitioner") paid $54,716 rent for 1992, 1993, and 1994. Following concessions, the issues for decision are:
1. Whether petitioners may deduct in 1992 $33,192.20 in rent that petitioner prepaid in...
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