Richard J. and Anna J. Sinsigalli - Page 2

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               Respondent determined deficiencies in petitioners' 1995 and            
          1996 Federal income taxes in the amounts of $2,209 and $2,591,2             
          respectively.  Respondent also determined an accuracy-related               
          penalty under section 6662(a) for 1995 in the amount of $442.  At           
          the time the petitions were filed, petitioners resided in Forest            
          Hill, Maryland.                                                             
               The issues are whether petitioners are entitled to                     
          miscellaneous deductions in excess of those allowed by respondent           
          for 1995, whether wages received by petitioner(s) in 1995 and               
          1996 are taxable, and whether petitioners are liable for an                 
          accuracy-related penalty pursuant to section 6662(a) for 1995.              
               The facts may be summarized as follows.  During the years in           
          issue, petitioner Richard J. Sinsigalli was employed by Frederick           
          Ward Associates as a design engineer.  For the taxable year 1995,           
          petitioners filed a joint Federal income tax return in which they           
          claimed itemized deductions in the amount of $31,332.3  Upon                
          examination, respondent disallowed $16,221 claimed as                       
          miscellaneous deductions.                                                   
               For the taxable year 1996, petitioners submitted a Form 1040           
          with "0.00" shown for their income and deductions.  Petitioners             


               2   The first page of the notice of deficiency for 1996                
          reflects a deficiency in the amount of $2,951.  This apparently             
          was due to a transposition error.  The computation page of the              
          notice shows a deficiency amount of $2,591, and, at trial,                  
          respondent verified that the lower amount was correct.                      
               3  Figures are rounded to the nearest dollar.                          




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