Richard William Corduan - Page 3




                                        - 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.                             




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