Jordon Jay Fingar - Page 3

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               After concessions by the parties,2 the issues for decision             
          are:  (1) Whether petitioner may claim Schedule A deductions for            
          taxes and interest in excess of the amounts allowed by respondent           
          for the taxable years in issue.  We hold he may, to the extent              
          set out below.  (2) Whether pursuant to section 162, petitioner             
          may claim unreimbursed business expense deductions in excess of             
          the amounts allowed by respondent for the taxable years in issue.           
          We hold he may, to the extent set out below.  (3) Whether                   
          pursuant to section 280A, petitioner is entitled to deduct home             
          office expenses for the taxable years in issue.  We hold he is              
          not.  (4) Whether for 1980, petitioner had unreported interest              
          income of $853.  We hold he did not.  (5) Whether for 1979,                 
          petitioner is entitled to a theft loss not previously claimed on            
          his return.  We hold he is not.  (6)  Whether pursuant to section           
          6651(a)(1) petitioner is liable for additions to tax for his                
          failure to timely file Federal income tax returns for the taxable           

          2    At trial and on brief, respondent concedes that petitioner             
          correctly reported his share of his then law firm's partnership             
          income of $96,340 for 1979 and $88,428 for 1980.                            
               Respondent further concedes that petitioner correctly                  
          claimed Keogh plan deductions of $4,766 for 1979 and $4,150 for             
          1980.                                                                       
          Respondent further concedes that petitioner provided                        
          receipts to verify the amounts set out below were spent by                  
          petitioner for 1979 and 1980.                                               
          Item         1979 Amount Verified       1980 Amount Verified                
          Taxes          $4,188                        -0-                            
          Interest            1,010                    -0-                            
          Auto                3,162                    $1,739                         
          Sailboat          13,572                     17,270                         
          T&E            3,109                       1,950                            




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