Michel L. Dixon - Page 2




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          deficiency and addition to tax and, further, claims an                      
          overpayment.                                                                
               The issues for decision are:  (1) Whether petitioner is                
          entitled to certain miscellaneous itemized deductions, some of              
          which were claimed on his 1993 Federal income tax return, and               
          others that support his claim for an overpayment; and (2) whether           
          petitioner is liable for the addition to tax under section                  
          6651(a)(1) for his failure to file a timely 1993 Federal income             
          tax return.                                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          At the time the petition was filed, petitioner resided in San               
          Clemente, California.                                                       
               Petitioner holds several master's degrees, including a                 
          master's degree in education received in 1976.  During 1993, he             
          was employed in a civilian capacity as an education specialist              
          for the U.S. Department of Defense.  His post of duty was Ft.               
          Baker, California.  At the time he was living in Novato,                    
          California, in an apartment that consisted of one bedroom, a                
          kitchen, a living room with a dining area, and a bathroom.  His             
          rent expense during that year was $650 per month.                           
               Petitioner was required to travel from time to time in                 
          connection with his employment with the Department of Defense,              
          and he did so during the year in issue.  He was entitled to                 





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