- 2 - All Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined deficiencies in petitioners' 1994 and 1995 Federal income taxes in the amounts of $990 and $473, respectively, and accuracy-related penalties under section 6662(a) for the years 1994 and 1995 in the amounts of $198 and $110, respectively. After concession by both parties,1 the issues for decision are: (1) Whether petitioners are entitled to claimed bad debt deductions under section 166 for 1994 and 1995; (2) whether petitioners failed to include interest income in their 1994 Federal income tax return; and (3) whether petitioners are liable for the accuracy-related penalties under section 6662. 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. Petitioners resided in Baldwin, Michigan, when the petition in this case was filed. All references to petitioner are to Clair Worthington. 1 Respondent conceded: (1) Petitioners are entitled to a legal and professional expense deduction for the year 1994 in the amount of $4,500; (2) petitioners did not receive taxable refund income in the year 1995 in the amount of $828; (3) petitioners are entitled to a tax preparation expense deduction for the year 1994 in the amount of $180, with $90 being allocated to Schedule A and $90 being allocated to Schedule C. Petitioners conceded that they are not entitled to the entire claimed legal and professional expense deduction of $6,080 for the year 1995 but are only entitled to such a deduction for that year in the amount of $2,080.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011