- 2 - Respondent determined deficiencies in petitioners' 1995 and 1996 Federal income taxes in the amounts of $2,209 and $2,591,2 respectively. Respondent also determined an accuracy-related penalty under section 6662(a) for 1995 in the amount of $442. At the time the petitions were filed, petitioners resided in Forest Hill, Maryland. The issues are whether petitioners are entitled to miscellaneous deductions in excess of those allowed by respondent for 1995, whether wages received by petitioner(s) in 1995 and 1996 are taxable, and whether petitioners are liable for an accuracy-related penalty pursuant to section 6662(a) for 1995. The facts may be summarized as follows. During the years in issue, petitioner Richard J. Sinsigalli was employed by Frederick Ward Associates as a design engineer. For the taxable year 1995, petitioners filed a joint Federal income tax return in which they claimed itemized deductions in the amount of $31,332.3 Upon examination, respondent disallowed $16,221 claimed as miscellaneous deductions. For the taxable year 1996, petitioners submitted a Form 1040 with "0.00" shown for their income and deductions. Petitioners 2 The first page of the notice of deficiency for 1996 reflects a deficiency in the amount of $2,951. This apparently was due to a transposition error. The computation page of the notice shows a deficiency amount of $2,591, and, at trial, respondent verified that the lower amount was correct. 3 Figures are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011