Pepi Schafler, f.k.a. Pepi Summer - Page 2

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          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.                                



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