John Allen and Glenna A. Lyle - Page 2

                                        - 2 -                                         

               The issues for our consideration are:  (1) Whether the                 
          correspondence in this case from respondent's employee estopped             
          respondent from determining a deficiency in petitioners' 1995               
          Federal income tax; (2) whether respondent correctly determined             
          that petitioners must recognize income from Social Security                 
          benefits in the amount of $7,643 for the taxable year 1995; (3)             
          whether petitioners are entitled to deduct $11,282 in alleged               
          job-hunting expenses; (4) whether petitioners are entitled to               
          deduct temporary living expenses of $5,240; (5) whether                     
          petitioners' gambling losses are limited to their income from               
          gambling for taxable year 1995; and (6) whether petitioners are             
          liable for the accuracy-related penalty under section 6662(a).              
          Separate Findings of Fact and Opinion are hereafter set forth               
          with respect to each of the first five issues.  Those portions of           
          the Stipulation of Facts that pertain to a particular issue are             
          incorporated by this reference in the Findings of Fact for the              
          issue to which they relate.                                                 
          I.  1994 Refund Letter                                                      
                                  FINDINGS OF FACT                                    
               At the time of the filing of the petition in this case,                
          petitioner John Allen Lyle resided in El Paso, Texas.  Petitioner           
          Glenna A. Lyle resided in Nashville, Tennessee.  Glenna A. Lyle             
          is a petitioner in this case because she joined in filing Federal           
          income tax returns with her husband John Allen Lyle (petitioner).           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011