- 2 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011