- 2 - and adopts the Special Trial Judge's opinion, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE DEAN, Special Trial Judge: Respondent determined a deficiency in petitioner's 1991 Federal income tax in the amount of $10,610 and an accuracy-related penalty under section 6662(a) in the amount of $2,122.2 After concessions,3 the issues for decision are: (1) Whether petitioner has substantiated various itemized deductions claimed on Schedule A of her 1991 Federal income tax return; and (2) whether petitioner is liable for an accuracy-related penalty under section 6662(a) for negligence or disregard of rules or regulations. 2Petitioner originally elected to have her case heard as a small tax case under Rule 172 and sec. 7463. However, in reviewing the record, we have determined that the sum of the deficiency disputed by petitioner and the penalty stipulated as an issue in this case ($2,122) is in excess of the $10,000 statutory limit for small tax cases. Rule 171(a); sec. 7463(a). The "S" designation of this case was therefore removed pursuant to our own motion. Rule 173; sec. 7463(d). 3For the year at issue, for which petitioner and her husband filed a joint income tax return, petitioner has conceded that she: (1) Is not entitled to Schedule C deductions in the amount of $13,125 claimed with respect to her husband's export-import business, and (2) failed to report taxable interest income in the amount of $190. Respondent has conceded that petitioner is entitled to Schedule C deductions in the amount of $17,575 with respect to her husband's taxi cab business. To the extent indicated below, respondent has also made concessions with respect to certain deductions claimed on petitioner's Schedule A. Finally, respondent acknowledges that, to the extent petitioner is liable for self-employment tax under sec. 1401, she will be allowed a corresponding deduction under sec. 164(f).Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011