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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners’ Federal
income tax of $4,202 and an accuracy-related penalty in the
amount of $36 for the taxable year 1996.
After concessions noted below, the issues for decision are:
(1) Whether petitioners are entitled to business and rental
expense deductions in excess of those allowed by respondent; (2)
whether petitioners are entitled to a child care credit in excess
of the amount allowed by respondent or, alternatively, entitled
to exclude from income the cost of child care services under
section 129(a); (3) whether petitioners received but did not
report dividend income; and (4) whether petitioners are liable
for an accuracy-related penalty under section 6662(a) for
negligence or disregard of rules or regulations.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Staten Island, New York, on the date the petition was filed in
this case.
The first issue for decision is whether petitioners are
entitled to business and rental expense deductions in excess of
those allowed by respondent. Petitioners claimed $14,920 of
business expenses on Schedule C, Profit or Loss From Business,
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Last modified: May 25, 2011