Manuel and Luella J. Delara - Page 3




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               Respondent determined a deficiency of $5,366 in petitioners'           
          Federal income tax for 1999, an addition to tax under section               
          6651(a)(1) in the amount of $122, and a penalty under section               
          6662(a) in the amount of $1,073.                                            
               In the notice of deficiency, respondent made several                   
          adjustments disallowing some of the itemized deductions claimed             
          by petitioners on Schedule A, Itemized Deductions, of their 1999            
          return.  In the stipulation filed with the Court, the parties               
          agreed that petitioners were entitled to charitable contribution            
          deductions of $330.70 instead of $6,968 claimed on their return;            
          that petitioners were entitled to a deduction for home mortgage             
          interest of $6,586.31 instead of $11,686 claimed on their return;           
          that petitioners were entitled to a deduction for taxes paid of             
          $2,575.56 instead of $2,117 claimed on their return; and that               
          petitioners were entitled to a deduction for moving expenses of             
          $391, for which no amount was claimed on their tax return.  The             
          other Schedule A adjustment was the disallowance in the notice of           
          deficiency of $9,781 claimed for unreimbursed employee expenses             
          and tax preparation fees.  No concessions were made by respondent           
          on these disallowed deductions.  With these concessions,                    
          petitioners conceded all other adjustments, including the                   
          addition to tax under section 6651(a)(1).  Thus, the issues                 
          remaining are whether petitioners are liable for the accuracy-              







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