- 2 - 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE NAMEROFF, Special Trial Judge: Respondent determined a deficiency in petitioner’s 1991 Federal income tax in the amount of $8,348, an addition to tax under section 6651(a)(1) in the amount of $99, and an accuracy-related penalty under section 6662(a) in the amount of $1,670. After concessions by the parties, the issues to be decided are: (1) Whether petitioner is entitled to a fuel tax credit of $8,249; and (2) whether petitioner is liable for the accuracy-related penalty. Petitioner resided in Gardena, California, at the time he filed his petition. Petitioner filed his 1991 Federal income tax return reflecting taxable interest income of $563, a Schedule E partnership loss of $42,168, a net operating loss carryover of $153,486, and itemized deductions of $10,696. Petitioner also reported rental income of $6,600 and claimed rental expenses of $5,638, resulting in a net income from rentals of $962. For some unexplained reason, the $962 profit was not carried forward to the face of the Form 1040. In the notice of deficiency, respondent disallowed the Schedule E partnership loss, the net operating loss deduction, and reduced the itemized deductions by 1 All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 Next
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