- 2 - the following deficiencies in, addition to, and accuracy-related penalties on petitioner's Federal income tax: Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 11990 $2,437 --- $487 1991 2,951 $414 590 1 For 1990, the deficiency and penalty determined in the notice of deficiency were $2,130 and $426, respectively. The increased deficiency and penalty were claimed in respondent's amended answer that asserts that petitioner is not entitled to a dependency exemption for his daughter. After concessions,2 the issues remaining for decision are: (1) Whether petitioner is entitled to a dependency exemption for his daughter in 1990 and his mother in 1991; (2) whether petitioner is entitled to head-of-household filing status for 1991; (3) whether the claimed bad debt deduction in the amount of $5,200 for 1990 should be treated as a business bad debt or a nonbusiness bad debt; (4) whether petitioner is entitled to a $9,100 theft loss deduction for 1991; (5) whether petitioner is entitled to a $2,500 deduction for unreimbursed employee business expenses incurred in 1991; (6) whether petitioner is liable for 2 With respect to 1990, petitioner has conceded that he is not entitled to a deduction in the amount of $12,000 for amounts withheld from his wages. For 1991, petitioner has conceded: (1) He is not entitled to a deduction for medical expenses claimed on Schedule A; (2) he may not claim his daughter, Jacqueline, as a dependent; (3) with respect to a claimed deduction for property taxes in the amount of $1,759, he is not entitled to a deduction of $845 (respondent concedes that petitioner is entitled to a deduction of $914); (4) with respect to a claimed deduction for unreimbursed employee business expenses in the amount of $3,200, he is not entitled to a deduction of $700; and (5) he is not entitled to claim a deduction for a casualty loss in the amount of $650.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011