Wayne M. and Janet L. Johnson - Page 2

                                        - 2 -                                         

          Unless otherwise indicated, section references are to the                   
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
               After concessions by the parties,1 the issues for decision             
          are:  (1) Whether petitioners are entitled to deduct an aggregate           
          partnership loss carryover in the amount of $3,313,240 for the              
          1994 taxable year;2 (2) whether petitioners are entitled to                 
          deduct charitable contributions in the amount of $2,024 for the             
          1994 taxable year; and (3) whether petitioners are liable for the           
          accuracy-related penalty pursuant to section 6662(a) for 1994.3             
          Petitioners filed a timely petition with this Court.  At the time           
          of filing the petition, petitioners resided in Yarmouth, Maine.             

               1    Petitioner Wayne Johnson concedes he is liable for                
          self-employment tax, and respondent concedes petitioners are                
          entitled to a credit for one-half the self-employment tax paid.             

               2    Neither party has questioned the Court’s jurisdiction             
          to adjudicate the partnership loss in this deficiency proceeding,           
          and we therefore assume that the partnerships are small                     
          partnerships within the meaning of sec. 6231(a)(1).                         
               3    The notice of deficiency contains adjustments to                  
          petitioners' medical expense deduction and earned income credit.            
          These are computational adjustments which will be affected by the           
          outcome of the other issues to be decided, and we do not                    
          separately address them.                                                    

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011