John R. Hernandez - Page 3




                                        - 2 -                                         
               Respondent determined deficiencies, additions to tax, and              
          penalties as follows:                                                       
                              Additions to Tax              Penalty                   
          Year   Deficiency   Sec. 6651(a)(1)   Sec. 6654   Sec. 6662(a)              
          1993    $16,422     $3,584.25      $591.02             ---                  
          1995      5,591     1,393.75            ---       $1,118.20                 
          1996      2,434     466.25              ---            486.80               
          1997   287          ---           ---       57.40                           
               After concessions,1 the issues for decision are: (1) Whether           
          interest income realized upon the redemption of tax certificates            
          is attributable to petitioner; (2) whether petitioner is entitled           
          to deductions related to rental properties for tax years 1995,              
          1996, and 1997; (3) whether petitioner is entitled to various               
          deductions on Schedule A for tax year 1995; (4) whether                     
          petitioner is entitled to head-of-household filing status for tax           
          year 1996; (5) whether petitioner is liable for the additions to            
          tax under section 6651(a)(1) for tax years 1993, 1995, and 1996;            
          (6) whether petitioner is liable for the addition to tax under              
          section 6654 for tax year 1993; and (7) whether petitioner is               




               1    For tax year 1993, respondent conceded that petitioner            
          is entitled to the filing status of married filing jointly and is           
          entitled to two exemptions for himself and his wife.  Petitioner            
          conceded that he failed to report pension income of $4,925 and              
          wages of $16,006.                                                           
               For taxable year 1995, respondent conceded that petitioner             
          is entitled to deduct charitable contributions of $1,651.                   
          Respondent also conceded that petitioner is entitled to                     
          miscellaneous itemized deductions of $2,276 on Schedule A,                  
          Itemized Deductions, for taxable year 1997.                                 




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