- 2 - 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. Respondent determined deficiencies in petitioner’s Federal income taxes and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1988 $2,162 $ 526.00 $133.98 1989 4,238 1,059.50 286.43 1990 3,786 946.50 249.05 After concessions by the parties,1 the issues for decision are: (1) Whether petitioner is entitled to the filing status of married filing jointly for the purposes of determining the amount of any liability for the 1990 taxable year; (2) whether petitioner is entitled to deductions for expenses incurred while working as a deckhand on a commercial fishing boat; (3) whether petitioner is entitled to deductions related to rental real property; (4) whether petitioner is entitled to casualty losses 1 Petitioner concedes that he received unemployment compensation, wages, and compensation as an independent contractor in at least the amounts determined by respondent. We therefore deem the gross income and self-employment tax issues to be conceded by petitioner for the years at issue. Respondent concedes that there was a mathematical error in the original determination as set forth in the notice of deficiency for the 1990 taxable year because petitioner was not given credit equal to one-half of the self-employment tax he owed for 1990. Accordingly, the deficiency for 1990 should be reduced by $127, with corresponding reductions in the secs. 6651 and 6654 additions to tax.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011