the settlements were specified

The following settlements indicate that the tax payer was allowed to deduct the losses and her original returns are deemed as "correct and accurate"

page 20

1. The petitioners are not liable for any deficiencies in income

 

tax, and are not due any overpayments of income tax, for taxable years

 

2005 and 2006.

 

2. The petitioners are not liable for penalties under the provisions

 

of I.R.C. § 6662(a) for taxable years 2005 and 2006.