- 2 - effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined deficiencies in petitioners’ Federal income taxes of $1,756, $8,480, and $6,059 for the taxable years 1993, 1994, and 1995, and an addition to tax under section 6651(a)(1) in the amount of $287 for taxable year 1995. The issue for decision is whether petitioners have substantiated various business expense deductions and itemized deductions.1 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 Jefferson, Louisiana, on the date the petition was filed in this case. The following concessions were made by the parties in the Stipulation of Facts. Respondent concedes the addition to tax under section 6651(a)(1). Petitioners concede that (1) they are not entitled to deductions in 1994 for bad debt expense and legal expense of $22,950 and $4,338, respectively, and (2) a State 1Adjustments in the notice of deficiency to medical expense deductions in 1994 and 1995, and the application of the floor on miscellaneous itemized deductions in each of the years in issue, are computational and will be resolved by the Court’s holding on the issue in this case.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011