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Respondent determined deficiencies in petitioners' Federal
income taxes and determined accuracy-related penalties under
section 6662(a) for the taxable years and in the amounts set
forth below:
Penalty
Year Deficiency Sec. 6662(a)
1992 $1,624 $168
1993 5,502 106
After concessions,1 the sole issue for decision is whether
petitioners are entitled to deduct unreimbursed employee expenses
incurred during the 1993 tax year in excess of those allowed by
respondent.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in Lawrenceville, Georgia.
References to petitioner are to Hansel Hamlin Johnson, Jr.
Petitioner is a software quality engineer with a bachelor’s
degree in industrial technology and electronics.
1
Petitioners concede the following: (1) They are not
entitled to interest deductions in the amount of $2,867 and
$2,602 for the 1992 and 1993 tax years, respectively; (2) they
are not entitled to unreimbursed employee expense deductions in
the amount of $2,817 or entitled to miscellaneous deductions in
the amount of $154 for the 1992 tax year; and (3) they are liable
for accuracy-related penalties pursuant to sec. 6662(a) in the
amounts of $168 and $106 for the 1992 and 1993 tax years,
respectively.
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