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Tax Court Rules of Practice and Procedure. Dollar amounts are
rounded to the nearest dollar.
Respondent determined deficiencies in petitioner’s Federal
income taxes of $8,228, $3,439, and $4,096, and accuracy-related
penalties of $1,646, $688, and $819 for the taxable years 1995,
1996, and 1997.
After concessions,1 the issues for decision are: (1)
Whether petitioner had unreported discharge of indebtedness
income; (2) whether petitioner has properly substantiated various
items for the years in issue, namely entitlement to (a) dependent
exemption deductions for his parents, (b) head of household
filing status, (c) certain charitable contribution deductions,
(d) certain limited liability company losses, (e) the deduction
of certain business expenses and the subtraction from gross
receipts of an amount of cost of goods sold, and (f) a
carryforward of a net operating loss from 1994 to the years in
issue; (3) whether, and if so to what extent, petitioner must
include in income a State income tax refund he received; and (4)
1Petitioner concedes that he received unreported dividend
income of $26 in 1995 and that an early distribution in 1997 of
$4,924 from a qualified retirement plan is income, but is not
wages, and is subject to the 10-percent additional tax under sec.
72(t). The parties also agree that the adjustments to capital
gains in the statutory notice of deficiency should be reduced
from $11,496, $2,044, and $1,649 for 1995, 1996, and 1997 to
$2,923, $39, and $143 for each respective year.
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Last modified: May 25, 2011