Robert Charles Fohrmeister - Page 2

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          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.                                                




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