Theodore L. Sizelove, Sr. and Elaine J. Sizelove - Page 3




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          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
               Respondent determined a $1,813 deficiency in petitioners’              
          2004 Federal income tax.  The issues for decision are whether               
          petitioners are entitled to claim:  (1) A bad debt deduction for            
          a “loan” they provided to their son; (2) a deduction for medical            
          and dental expenses; (3) a deduction for the business use of                
          their home that is attributable to the operation of a nonprofit             
          activity; and (4) a miscellaneous itemized deduction for vehicle            
          expenses incurred in the operation of a nonprofit activity and in           
          Mr. Sizelove’s employment.                                                  
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by reference.  At the time the petition             
          was filed, petitioners resided in California.                               
               On their timely filed 2004 joint Form 1040, U.S. Individual            
          Income Tax Return, petitioners claimed a $10,000 bad debt                   
          deduction for a “loan” made to their son and his new wife during            
          2004 and an $8,460.38 deduction for medical and dental expenses             
          (before application of the 7.5-percent floor).  Petitioners                 
          substantiated $2,551 in medical expenses, consisting of payments            
          to Medicare and their health insurance provider, Teamsters                  
          Benefit Trust.                                                              







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