- 2 - petitioner's 1992 Federal income tax in the amount of $4,158 and an addition to tax under section 6651(a) in the amount of $1,039. After concessions by respondent,2 the issues remaining for decision are: (1) Whether petitioner is entitled to deduct a theft loss claimed on her return; (2) whether petitioner is entitled to deduct legal fees claimed on her return in excess of the amount allowed by respondent; (3) whether petitioner is entitled to deduct medical expenses claimed on her return in excess of the amount allowed by respondent; (4) whether petitioner is entitled to deduct charitable contributions claimed on her return in excess of the amount allowed by respondent; and (5) whether petitioner is subject to the addition to tax under section 6651(a) for failure to file a timely return. Background For 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. At the time that the petition was filed, petitioner resided at North Bethesda, Maryland. Petitioner signed her 1992 Federal income tax return on December 14, 1993, and respondent received it on December 17, 2 Respondent concedes that: (1) Petitioner paid medical expenses in the amount of $2,002, and (2) petitioner is entitled to a miscellaneous itemized deduction for the cost of a safe deposit box in the amount of $65. Respondent made concessions as to other deductions. These concessions are set forth in the discussions relating to the specific issues.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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