- 2 - Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. Respondent determined deficiencies in petitioner’s Federal income taxes of $8,228, $3,439, and $4,096, and accuracy-related penalties of $1,646, $688, and $819 for the taxable years 1995, 1996, and 1997. After concessions,1 the issues for decision are: (1) Whether petitioner had unreported discharge of indebtedness income; (2) whether petitioner has properly substantiated various items for the years in issue, namely entitlement to (a) dependent exemption deductions for his parents, (b) head of household filing status, (c) certain charitable contribution deductions, (d) certain limited liability company losses, (e) the deduction of certain business expenses and the subtraction from gross receipts of an amount of cost of goods sold, and (f) a carryforward of a net operating loss from 1994 to the years in issue; (3) whether, and if so to what extent, petitioner must include in income a State income tax refund he received; and (4) 1Petitioner concedes that he received unreported dividend income of $26 in 1995 and that an early distribution in 1997 of $4,924 from a qualified retirement plan is income, but is not wages, and is subject to the 10-percent additional tax under sec. 72(t). The parties also agree that the adjustments to capital gains in the statutory notice of deficiency should be reduced from $11,496, $2,044, and $1,649 for 1995, 1996, and 1997 to $2,923, $39, and $143 for each respective year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011