2
$5,952 and $6,471.50, and an accuracy-related penalty under
section 6662(b)(1) for 1990 in the amount of $1,294.30.
After concessions,2 the issues for decision are: (1)
Whether the distribution received by petitioners from an
individual retirement account (IRA) with Fidelity Magellan Fund
(Fidelity) in 1990 in the amount of $16,831.81 is taxable; (2)
whether petitioners are entitled to an adjustment to income in
the amount of $1,614.91 attributable to petitioners' IRA
distribution from Fidelity in 1990; (3) whether petitioners
failed to report a distribution from the Civil Service Retirement
System (CSRS) in 1990 in the amount of $464; (4) whether
petitioners failed to report a distribution from the U.S.
Department of Agriculture (DOA) National Finance Center in 1990
of $580; (5) whether petitioners are liable for a penalty
pursuant to section 72 for premature distributions in the
aggregate amount of $17,875.81 in 1990; (6) whether petitioners
are entitled to rental expense deductions for 1989 and 1990 in
2
Petitioners concede that: (1) They overstated their rental
income for 1989 and 1990 by $400 and $898, respectively; (2) they
are not entitled to rental depreciation of $14,673 for 1989; (3)
they are not entitled to deduct capital losses of $3,000 for
1990; (4) they failed to report an individual retirement account
distribution of $16,831.81; (5) they are not entitled to Schedule
A deductions claimed in 1990 for job and miscellaneous expenses
of $4,785.95, and medical expenses of $1,744.27; and (6) they are
not entitled to itemize for 1990 because the standard deduction
exceeds the allowable itemized deductions. Respondent concedes
that petitioners repaid unemployment compensation in 1990 in the
amount of $1,715 and are entitled to rental depreciation of
$2,889 for 1990.
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