- 5 - reported by petitioner's returns, which are stipulated in evidence herein. 2. With respect to the itemized deductions (Schedule A) on petitioner's return for the year 1992, respondent disallowed the amount of $28,985 as deductions; petitioner, however, claimed only $29,495 in itemized deductions on that return, of which respondent has conceded $1,306. We know of no basis for respondent's determination of a disallowed deduction in excess of petitioner's claim, after allowing for respondent's concession. 3. With respect to the year 1993, respondent disallowed $28,526 of itemized deductions; petitioner had claimed $29,870, and after respondent's concession of $1,344, the net disallowance by respondent of $28,526 appears correct in accordance with the present record. The above discrepancies with respect to the disallowances by respondent as compared to the deductions as claimed by petitioner in the 2 years in question will have to be reconciled in the necessary computation herein under Rule 155. With regard to the penalties in tax for the years 1992 and 1993, determined herein by respondent, section 6662(a) imposes a penalty in the amount of 20 percent of the portion of the underpayment attributable to negligence. Petitioner is liable for an accuracy-related penalty for negligence in the preparation and filing of his 1992 and 1993 tax returns. Petitioner failed to substantiate any of the deductions taken on the 1992 and 1993Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011