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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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