- 3 - 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 1,950Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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