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Robert Cotton, Jr., Docket No. 6701-99
Penalty
Year Deficiency Sec. 6662(a)
1994 $6,749 $514
1995 8,007 420
1996 4,451 428
Sharon Cotton, Docket No. 7005-99
Penalty
Year Deficiency Sec. 6662(a)
1994 $2,684 $336
1996 4,013 545
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions by petitioners (hereinafter referred to
individually as Mrs. Cotton and Mr. Cotton),1 the issues for
1 Mr. Cotton concedes that he is not entitled to the
following: (1) Head-of-household filing status under sec. 2(b)
for 1994 and 1996; (2) single filing status for 1995; (3)
dependent care credit pursuant to sec. 21 in the amount of $911
for 1994 (respondent erroneously categorized the credit as the
child care credit under sec. 24, which did not go into effect
until 1998); (4) Schedule C, Profit or Loss From Business, loss
in the amount of $10,150 for 1995; (5) deduction for a safety
deposit box in 1995; (6) deductions for personal property and
real estate taxes in the respective amounts of $600 and $1,300
for 1994 and 1995; and (7) deductions for charitable
contributions in the amounts of $4,650, $4,150, and $3,701 for
1994, 1995, and 1996, respectively.
Mrs. Cotton concedes that she is not entitled to the
(continued...)
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