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the year in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
The issues for decision are: (1) Whether a settlement
payment that petitioner received from Central Washington
University (CWU) is excludable from his gross income under
section 104(a)(2); (2) whether petitioner has substantiated the
nature and amount of various deductions he claimed on the
Schedule C attached to his 1993 Federal income tax return;
(3) whether petitioner is entitled to a casualty loss deduction;
(4) whether petitioner is entitled to a deduction for charitable
contributions in an amount greater than the amount determined by
respondent; (5) whether petitioner is entitled to a deduction for
unreimbursed employee business expenses; (6) whether petitioner
is entitled to an individual retirement account (IRA) deduction;
and (7) whether petitioner is liable for the accuracy-related
penalty under section 6662(a).
For purposes of convenience and clarity, we have combined
the findings of fact and discussion of pertinent legal issues.
Some of the facts were stipulated, and those facts are so found
and are incorporated herein by reference. Petitioner resided in
Yakima, Washington, at the time the petition was filed in this
case.
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