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All references to petitioner are to Jack S. Morris.
Respondent determined deficiencies in petitioners’ Federal income
taxes in the amounts of $3,563 and $4,744 for tax years 1996 and
1997, respectively.1 After concessions,2 the issues for decision
are: (1) Whether petitioner is a statutory employee; (2) whether
petitioner is entitled to an adjustment for cost of goods sold;
(3) whether petitioner is entitled to deductions for home office
expenses under section 280A; and (4) whether petitioner is
entitled to various Schedule C deductions.
1 After trial, the parties stipulated that petitioner
Dorothy Morris (now Dorothy Kirkpatrick) is entitled to relief
from joint liabilities determined for the 1996 and 1997 tax years
pursuant to sec. 6015(b).
2 Respondent concedes that petitioner is entitled to
deductions for union dues of $384 and $390 in 1996 and 1997,
respectively. Respondent concedes that petitioner paid $184 and
$210 for uniforms in 1996 and 1997, respectively. Sec. 67 imposes
a 2-percent floor of adjusted gross income on miscellaneous
itemized deductions. After concessions and our holdings, the
miscellaneous itemized deductions do not exceed the 2-percent
floor for 1996 and 1997.
Respondent concedes that petitioner is entitled to
deductions for home mortgage interest of $13,908 and $13,750 for
1996 and 1997, respectively. On their Federal income tax
returns, petitioners deducted home mortgage interest of $9,482
and $9,375 for 1996 and 1997, respectively.
Petitioners claimed a deduction of $1,200 in 1996 for legal
and professional services. Petitioner did not address this
deduction at trial. As a result, petitioner is deemed to have
conceded the item. See Rules 142(a), 149(b); Sundstrand Corp. v.
Commissioner, 96 T.C. 226, 344 (1991); Pearson v. Commissioner,
T.C. Memo. 2000-160.
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