Alice Pauline Browne, A.K.A. A. Pauline Browne - Page 2

                                        - 2 -                                         
               Respondent determined deficiencies in petitioner's Federal             
          income taxes, an addition to tax, and accuracy-related penalties            
          for the years indicated:                                                    
                                        Addition to Tax     Penalties                 
               Year      Deficiency     Sec. 6651(a)(1)    Sec. 6662(a)               
               1992      $4,438         $221.90             $638.40                   
               1993      $2,730         -                   $546.00                   
               After a concession by petitioner,2 the issues remaining for            
          decision are:  (1) Whether petitioner is entitled to Schedule C             
          business expense deductions in excess of the amounts allowed by             
          respondent; (2) whether petitioner is liable for the section                
          6651(a)(1) addition to tax for 1992; and (3) whether petitioner             
          is liable for the section 6662(a) accuracy-related penalties for            
          1992 and 1993.                                                              
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in               
          Royal Palm Beach, Florida, on the date the petition was filed in            
          this case.                                                                  


          2         Petitioner concedes that respondent properly determined           
          that one-half of the Social Security benefits she received during           
          1992 must be included in her gross income for her 1992 taxable              
          year.  On her 1992 return, petitioner correctly reported her                
          Social Security benefits received in the amount of $8,885 but               
          mistakenly entered the taxable amount of such benefits on the               
          line labeled "other income".  The proper adjustment to                      
          petitioner's taxable Social Security benefits for 1992 is only              
          $2,247.50, which represents the difference between the taxable              
          amount reported on the wrong line ($2,195) and the correct                  
          taxable amount ($4,442.50).                                                 




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