- 2 - $14,409 and $2,882, respectively.2 The issues for decision3 are: (1) Should the determinations for 1995 increasing peti- tioner’s income and disallowing certain claimed deductions that respondent has not conceded be sustained? We hold that they should except to the extent provided herein. (2) Is petitioner entitled for 1995 to a theft loss under section 165? We hold that he is not. (3) Is petitioner liable for 1995 for the accuracy-related penalty under section 6662(a)? We hold that he is. FINDINGS OF FACT Some of the facts have been stipulated and are so found.4 Petitioner resided in Alaska, and had a mailing address in Montana, at the time the petition was filed. 2Although the notice of deficiency issued to petitioner for 1995 (notice) shows that respondent determined a deficiency in, and an accuracy-related penalty under sec. 6662(a) on, peti- tioner’s tax of $14,409 and $2,882, respectively, computational schedules that are attached to the notice show a deficiency of $14,446 and an accuracy-related penalty of $2,889.20. Because respondent has admitted in the answer that the deficiency in, and accuracy-related penalty on, petitioner’s tax determined in the notice are $14,409 and $2,882, respectively, we shall disregard for purposes of this case the erroneous numbers shown in the computational schedules that are attached to the notice. 3There are other issues relating to certain determinations in the notice that are computational in that their resolution flows automatically from our resolution of other determinations in the notice that we address herein. 4Unless otherwise indicated, our Findings of Fact and Opin- ion pertain to the year at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011