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Federal income taxes: Additions to
Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)1 6654(a)
1982 $1,441 $360 $72 $140
1983 884 221 44 54
1984 902 226 45 57
1985 2,122 531 106 121
1 In addition, respondent determined that petitioner was liable for an addition to
tax under sec. 6653(a)(2) in the amount of 50 percent of the interest payable with
respect to the portion of the underpayment attributable to negligence for each of
the years in issue.
In the notice of deficiency, respondent determined that
petitioner and her former spouse, Dan Thompson (Mr. Thompson),
did not file Federal income tax returns for taxable years 1982,
1983, 1984, and 1985. In addition, respondent determined that
petitioner was married and domiciled in a community property
State and computed her income tax liability in accordance with
community property laws. Respondent determined that petitioner's
community share of gross receipts from National Cartage Co. was
$28,505 in 1982; $24,147 in 1983; $24,971 in 1984; and $36,750 in
1985. Further, respondent determined that petitioner earned
interest income of $5 in 1982 and $5 in 1983. Respondent allowed
the following business expenses:
Gross Expense Total Community
Year Receipts X Percent =Expense +Deprec.1 = Deduction Share (1/2)
1982 $57,009 41 $23,374 $8,000 $31,374 $15,687
1983 48,294 41 19,801 8,000 27,801 13,901
1984 49,941 41 20,476 8,000 28,476 14,238
1985 73,500 41 30,135 8,000 38,135 19,068
1 The depreciation is based on a tractor placed in service in 1980 with a cost of
$80,000, zero salvage value, 10-year useful life, and the straight-line method.
In addition, respondent allowed excess itemized deductions as
follows:
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Last modified: May 25, 2011