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It is determined that you received an award in
the amount of $314,174.00 from Thrifty which
was not reported on your return for the taxable
year ended December 31, 1994. This amount is
determined to be taxable to you because you
have failed to establish that this amount is
excludable from gross income under the provi-
sions of the Internal Revenue Code. Accordingly,
income is increased in the amount of $314,174.00.
Respondent also adjusted the miscellaneous itemized
deductions claimed on Schedule A of petitioners' return,
$610, by adding $194,595 to arrive at total miscellaneous
itemized deductions of $195,205, before taking into account
the 2-percent floor as required by section 67(a). It
appears that the additional miscellaneous itemized
deductions allowed in the notice of deficiency relate to
the attorney's fees that petitioner paid with respect to
his suit against Thrifty, but the record does not readily
disclose how respondent computed the amount of the
adjustment. The parties agree that that amount is not
correct and the correct amount of the additional
miscellaneous itemized deductions is $129,698.70, computed
as follows:
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Last modified: May 25, 2011