- 2 -
Respondent determined deficiencies in petitioners' Federal
income taxes for 1991 and 1992 in the amounts of $2,667 and
$3,654, respectively, and penalties for fraud pursuant to section
6663(a) in the amounts of $1,475 and $2,111, respectively.
After concessions by petitioners,2 the issues remaining for
decision are: (1) Whether petitioners are entitled to charitable
contribution deductions for 1991 and 1992 in excess of the
amounts allowed by respondent; (2) whether petitioners are
entitled to a casualty loss deduction for 1992; and (3) whether
petitioners are liable for the section 6663(a) penalty for fraud
for 1991 and 1992.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Jacksonville,
Florida, on the date the petition was filed in this case.
Petitioner husband (Mr. Daniel) is a retired Marine Corps
veteran. Petitioner wife (Mrs. Daniel) works for respondent in
the Collections Division. She was initially hired in December
1983 as a clerk and was later promoted to the position of account
representative/tax examiner. Her responsibilities include
contacting delinquent taxpayers, securing payments, and setting
up payment plans. She is not involved in the preparation of
2 Petitioners concede that they received and failed to
report interest income in the amounts of $50.49 and $52.17 for
1991 and 1992, respectively. Petitioners also concede that they
are only entitled to a deduction for real estate taxes for 1992
in the amount of $901, as determined by respondent.
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