- 5 - deficiency deductions of $1,551, $3,553, and $2,563. Respondent concedes in his trial memorandum that petitioners should have received current-year expense deductions5 of $3,102, $3,242, and $1,992 in the notice of deficiency. Respondent concedes in the stipulation that petitioners are entitled to additional deductions of $992, $1,244, and $2,738. Finally, respondent conceded at trial the initial adjustment to the travel expenses in 1993, thereby conceding that petitioners were entitled to a deduction of $4,094 in the notice of deficiency. Thus, under respondent’s multiple concessions, petitioners are entitled to deductions for travel expenses of $5,086 in 1993, $4,486 in 1994, and $4,730 in 1995. The following table reflects items which remain at issue in this case after the various concessions. The amounts of deductions claimed by petitioners on their Federal income tax returns are shown, along with the total allowances and concessions by respondent. 1993 1994 1995 Allowed/ Allowed/ Allowed/ Claimed Conceded Claimed Conceded Claimed Conceded Business expenses (Sch. C) Writing/lecturing Interest expense $5,342 $3,925 $6,845 $2,774 $11,303 $1,097 Travel expense 6,355 4,486 6,790 4,730 Travel/writing/consulting Travel expense 2,676 -0- Other expense 725 -0- Itemized deductions (Sch. A) Mortgage interest expense 12,853 8,6531 Miscellaneous 10,202 856 11,998 5,626 9,147 1,709 5See supra note 3 regarding the issue of capitalization.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011