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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.
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Last modified: May 25, 2011