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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ Federal
income taxes of $12,278, $6,142, and $7,074 and accuracy-related
penalties of $2,456, $1,228, and $1,415 for the taxable years
1993, 1994, and 1995.
After concessions, the issues for decision are: (1) Whether
petitioners are entitled to charitable contribution deductions in
excess of the amounts allowed and conceded by respondent for 1993
and 1994; (2) whether petitioners recognized unreported gain on
the sale of certain property in 1993; (3) whether petitioners
made deductible interest payments in 1994 and 1995 that were not
claimed as deductions on their returns; and (4) whether
petitioners are liable for the accuracy-related penalties under
section 6662(a).1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Ashland, Missouri, on the date the petition was filed in this
case.
1With respect to issues one and two, respondent concedes
petitioners are entitled to an additional deduction for
charitable contributions in 1993 and a reduction in the amount of
the gain recognized, as discussed below. We treat determinations
made in the notice of deficiency but not addressed here as having
been conceded by petitioners because they were not disputed
either in the petition or at trial.
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