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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined a Federal income tax
deficiency for petitioner’s 1994 taxable year in the amount of
$5,846. Respondent also determined a civil fraud penalty of
$4,385 for 1994, pursuant to section 6663.
The issues for decision are as follows:
(1) Whether petitioner has established entitlement to
deductions claimed for medical expenses, charitable
contributions, casualty losses, and employee business or
miscellaneous expenses; and
(2) whether petitioner is liable for the section 6663 civil
fraud penalty or, in the alternative, the section 6662(a)
accuracy-related penalty.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations filed by the parties, with accompanying
exhibits, are incorporated herein by this reference.
Linda D. Fason resided in Lynwood, California, at the time
of filing her petition in this case. On her 1994 income tax
return, petitioner reported having incurred, and took
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