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(1) Whether petitioners are entitled to itemized deductions
as claimed on Schedules A in excess of the amounts allowed by
respondent. We hold that they are not.
(2) Whether petitioners are entitled to deductions for
business expenses as claimed on Schedules C. We hold that they
are not.
(3) Whether petitioners are entitled to six dependency
exemptions as claimed for 1990 and five dependency exemptions as
claimed for 1991. We hold that they are entitled to two of the
six exemptions claimed for 1990 and two of the five exemptions
claimed for 1991.
(4) Whether petitioners are entitled to child care credits
as claimed. We hold that they are not.
For simplicity, we shall first set forth the relevant
background facts and general legal principles; we will then
combine our findings of fact and opinion with respect to each
issue.
Background Facts
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein by this reference. Petitioners, husband
and wife, filed joint tax returns for both years in issue. The
returns were prepared by a paid tax preparer. Petitioners resided
in Fort Washington, Maryland, at the time they filed their
petition.
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