David Daniel and Annette Daniel - Page 2

                                                 - 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.                                          


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