- 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.
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