- 2 - Respondent determined the following deficiencies in petitioners' Federal income taxes, additions to tax, and penalties: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1990 $4,383 $202 $ 877 1991 5,481 91 1,096 1992 1,964 58 393 After concessions by respondent,2 the issues for decision are: (1) Whether petitioners are entitled to charitable contribution deductions, under section 170(a) for each of the years in question, for contributions to a local singing group; (2) whether petitioners are entitled to educational expense deductions, under section 162(a) for each of the years in question; (3) whether petitioners are precluded, under section 280A for each of the years in question, from deduction of losses incurred from rental properties; (4) in the event section 280A is not applicable to petitioners' rental properties, whether petitioners have substantiated certain expenses; (5) in the event section 280A is not applicable to petitioners' rental properties, 2 At trial, respondent conceded the addition to tax under sec. 6651(a)(1) for 1991. Respondent, at trial, made several other concessions, principally with respect to the substantiation of various expenses that were disallowed in the notices of deficiency. Those concessions are noted in the body of the opinion. A Rule 155 computation will be necessary in these cases.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011