- 2 - Penalty Year Deficiency Sec. 6662 1998 $30,752 $6,150 1999 32,136 6,427 After concessions,2 the issues for decision are as follows: (1) Whether petitioners are entitled to deduct net operating loss carryforwards computed with respect to 1975 on their Federal income tax returns for 1998 and 1999; (2) whether petitioners are entitled under section 170 to deduct charitable contributions for the years 1998 and 1999 in excess of those already allowed by respondent; and (3) whether petitioners are liable under section 6662(a) and (b) for accuracy-related penalties due to negligence and substantial understatement of income tax for 1998 and 1999. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts is incorporated herein by this reference. Petitioners, who filed joint Forms 1040, U.S. Individual Income Tax Return, for 1998 and 1999, resided in Los Alamos, New Mexico, when their petition in this case was filed. 2In the notice of deficiency, respondent determined that petitioners were not entitled to home mortgage interest deductions for 1998 and 1999 in the amounts of $2,880 and $1,617, respectively. Respondent conceded these amounts in the stipulation of facts. Also at issue in this case are adjustments to itemized deductions for 1998 and 1999, which are computational. Additionally, petitioners conceded that a net operating loss (NOL) from 1976 had been used completely in years before the years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011