Gabriel M. Daya, et al. - Page 17




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          also claimed a mortgage interest deduction of $9,303 and a                  
          property tax deduction of $1,532.                                           
               In notices of deficiency, respondent determined Gabriel was            
          not entitled to dependency exemption deductions for Mahmoud and to          
          head of household filing status for tax years 1995 and 1996.                
          Respondent further determined Gabriel was not entitled to                   
          deductions for home mortgage interest expense and for property tax          
          expense in 1995.  Respondent disallowed all but 5 percent of                
          Gabriel’s deductions for home mortgage interest expense and for             
          property tax expense in 1996.  As a result of respondent’s                  
          adjustments, Gabriel’s itemized deductions for each of the years            
          in issue were reduced to amounts less than the allowable standard           
          deduction.  Gabriel’s tax liability, therefore, was determined              
          using the standard deduction for each of the years in issue.                
               Respondent determined Morhaf was not entitled to head of               
          household filing status and to deductions for mortgage interest             
          expense and property tax expense in taxable year 1995.                      
          Respondent’s determination reduced Morhaf’s itemized deductions to          
          an amount less than the standard deduction in 1995; thus, Morhaf’s          
          tax liability was determined using the standard deduction.                  
                                        OPINION                                       
               Deductions are strictly a matter of legislative grace, and             
          taxpayers must satisfy the specific requirements for any deduction          
          claimed.  See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84                






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