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Accuracy-related Penalties
Year Deficiency Sec. 6662(a)
1991 $8,997 $1,799
1992 4,069 814
1993 857 171
All section references are to the Internal Revenue Code in effect
for the years in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure. After concessions,1 the issues
for decision are:
(1) Whether various costs incurred during 1991 that were
related to buildings used in petitioner's farming and breeding
businesses may be deducted under section 162 as ordinary and
necessary business expenses or must be capitalized under section
263 as expenditures made pursuant to a general plan of capital
improvements;
(2) whether petitioner is entitled to an interest expense
deduction in the amount of $2,178 for the year 1992;
1 Petitioner concedes that she is not entitled to
exemptions in the amounts of $4,300 and $4,600 for the years 1991
and 1992, respectively, for her two minor children, Sara
Elizabeth Obertein and Mary Jo Louise Obertein. Petitioner also
concedes that she is not entitled to an exemption for her
daughter Mary Jo Louise Obertein for 1993. Respondent concedes
that petitioner is entitled to an exemption for her daughter Sara
Elizabeth Obertein for 1993. Respondent also concedes that
petitioner is entitled to exemptions for her brother, George
Heiman David Schroeder for the years 1991, 1992, and 1993.
Respondent further concedes that petitioner is entitled to head
of household filing status for the years 1991, 1992, and 1993.
Respondent further concedes that petitioner is entitled to a
$1,046 interest deduction in 1993.
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Last modified: May 25, 2011