MEMORANDUM OPINION
CLAPP, Judge:
Respondent determined a deficiency of $10,669 in petitioner's 1990 Federal income tax and a penalty of $2,134 pursuant to section 6662(a).
After concessions by the parties, the issues for decision are:
(1) Whether petitioner's expenditures related to residential real property were paid or incurred in carrying on a trade or business pursuant to section 162 or for the production of income pursuant to section...
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