George Coloney - Page 1

                                 T.C. Memo. 1999-194                                  


                               UNITED STATES TAX COURT                                


                            GEORGE COLONEY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 23087-97.                    Filed June 16, 1999.           


                    On the facts, Held: (1) P may not deduct gambling                 
               losses in excess of amounts allowed by R; (2) P's deduction            
               for State income taxes is limited to the amount of New York            
               State income tax withheld by P's employer in 1994; and (3)             
               R's determination that there is an accuracy-related penalty            
               due from P under sec. 6662(a), I.R.C., for the 1994 taxable            
               year is sustained.                                                     


               Edmund J. Mendrala, for petitioner.                                    
               Timothy V. Mulvey, for respondent.                                     











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