Vashon C. and Beverly C. Jackson - Page 2




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               Respondent determined deficiencies in petitioners' Federal             
          income taxes for 1990, 1991, and 1992 in the amounts of $6,959,             
          $7,039, and $8,013, respectively, and accuracy-related penalties            
          pursuant to section 6662(a) in the amounts of $303, $239, and               
          $232, respectively.                                                         
               The issues for decision are:  (1) The amount of rents                  
          received by petitioners during the taxable years in issue; (2)              
          whether petitioners are entitled to any deductions with respect             
          to the rented property; (3) whether petitioners are entitled to             
          any deductions for unreimbursed employee business expenses; (4)             
          whether petitioners are entitled to charitable contribution                 
          deductions in excess of the amounts allowed by respondent; and              
          (5) whether petitioners are liable for the section 6662(a)                  
          accuracy-related penalties.                                                 
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioners resided in Chesapeake,               
          Virginia, on the date the petition was filed in this case.                  
               Petitioner husband worked as an auditor for the Army Corps             
          of Engineers during the taxable years in issue.  Petitioner wife            
          worked as a schoolteacher during the taxable years in issue.                
          Petitioners reside at 2105 Hollins Court in Chesapeake, Virginia.           


          1(...continued)                                                             
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     




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