- 2 -- 2 -
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether petitioner is
entitled to miscellaneous itemized deductions in excess of
amounts conceded by respondent, and (2) whether petitioner is
liable for an accuracy-related penalty under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Spring Valley, California, when the petition in this case was
filed.
Petitioner and Judy Barber (Ms. Barber) were married in
October 1994. Consequently, petitioner resided with Ms. Barber
until April 11, 1995. On April 11, 1995, petitioner moved out of
the marital home because of marital difficulties. Petitioner's
marriage to Ms. Barber was annulled on September 21, 1995.
Petitioner and Ms. Barber filed a joint Federal income tax
return for the year 1994. On their 1994 Federal income tax
return, petitioner and Ms. Barber claimed miscellaneous itemized
deductions of $37,066. In the case of an individual, the
miscellaneous itemized deductions for any taxable year shall be
allowed only to the extent that the aggregate of such deductions
exceeds 2 percent of the adjusted gross income. See sec. 67(a).
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011