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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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