- 2 - petitioner's 1991 Federal income tax in the amount of $6,062 and an accuracy-related penalty under section 6662(a) in the amount of $1,212. After a concession by petitioner,2 the issues remaining for decision are: (1) Whether petitioner is entitled to a business bad debt deduction in the amount of $4,500 claimed on Schedule C; (2) whether petitioner failed to report wage income in the amount of $23.20; (3) whether petitioner is entitled to a claimed casualty loss deduction in the amount of $6,490; (4) whether petitioner is liable for the 10-percent additional tax imposed by section 72(t), in regard to distributions he received from an employer-provided pension plan and an individual retirement account (IRA); and (5) whether petitioner is liable for the accuracy-related penalty under section 6662(a).3 For the purpose of convenience, we have combined the findings of fact and discussion of pertinent legal issues. Some of the facts have been stipulated, and they are so found. The 2 Petitioner concedes that he made a mathematical error on one of his Schedules C in the amount of $100. Due to the resulting increase in petitioner's adjusted gross income, claims for medical expense deductions were reduced by $7.50, claims for casualty loss deductions were reduced by $10, and claims for miscellaneous deductions were reduced by $2. Therefore, the total adjustment attributable to petitioner's concession is $119.50. 3 Respondent's notice of deficiency also reduced petitioner's claimed medical expense and miscellaneous deductions. We regard these adjustments as computational and do not separately address them.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011