Joel Baker - Page 2

                                        - 2 -                                         
          the following deficiencies in, addition to, and accuracy-related            
          penalties on petitioner's Federal income tax:                               
                    Addition to Tax     Accuracy-Related Penalty                      
          Year   Deficiency    Sec. 6651(a)(1)           Sec. 6662(a)                 
          11990     $2,437            ---                     $487                    
          1991      2,951           $414                      590                     
               1  For 1990, the deficiency and penalty determined in the              
          notice of deficiency were $2,130 and $426, respectively.  The               
          increased  deficiency and penalty were claimed in respondent's              
          amended answer that asserts that petitioner is not entitled to a            
          dependency exemption for his daughter.                                      
               After concessions,2 the issues remaining for decision are:             
          (1) Whether petitioner is entitled to a dependency exemption for            
          his daughter in 1990 and his mother in 1991; (2) whether                    
          petitioner is entitled to head-of-household filing status for               
          1991; (3) whether the claimed bad debt deduction in the amount of           
          $5,200 for 1990 should be treated as a business bad debt or a               
          nonbusiness bad debt; (4) whether petitioner is entitled to a               
          $9,100 theft loss deduction for 1991; (5) whether petitioner is             
          entitled to a $2,500 deduction for unreimbursed employee business           
          expenses incurred in 1991; (6) whether petitioner is liable for             

          2  With respect to 1990, petitioner has conceded that he is                 
          not entitled to a deduction in the amount of $12,000 for amounts            
          withheld from his wages.  For 1991, petitioner has conceded:  (1)           
          He is not entitled to a deduction for medical expenses claimed on           
          Schedule A; (2) he may not claim his daughter, Jacqueline, as a             
          dependent; (3) with respect to a claimed deduction for property             
          taxes in the amount of $1,759, he is not entitled to a deduction            
          of $845 (respondent concedes that petitioner is entitled to a               
          deduction of $914); (4) with respect to a claimed deduction for             
          unreimbursed employee business expenses in the amount of $3,200,            
          he is not entitled to a deduction of $700; and (5) he is not                
          entitled to claim a deduction for a casualty loss in the amount             
          of $650.                                                                    



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011