- 13 - Discussion For 1992, respondent's disallowance of $4,329 in itemized deductions and corresponding allowance of a standard deduction of $3,600 are computational adjustments that will be resolved by the Court's holding on whether BRVC was an activity not engaged in for profit for that year. Also, for 1993, respondent's determination of $2,598 in hobby income and allowance of an additional $914 in itemized deductions3 are computational adjustments that will be resolved by the Court's holding on whether BRVC was an activity not engaged in for profit for 1993. Additionally, for 1993, respondent determined that petitioner realized income from an unreported State income tax refund of $1,227. Respondent contends that this adjustment is computational based on the determination for 1992 that BRVC constituted an activity not engaged in for profit. The Court does not agree with respondent's treatment of this item for the following reasons. In order for a taxpayer to be required to include a State income tax refund in income, the taxpayer must have received a 3 Due to the increase in petitioner's adjusted gross income, petitioner's itemized deductions for medical and dental expenses were phased out entirely. However, in connection with BRVC, petitioner was allowed an additional $2,598 in miscellaneous itemized deductions subject to the 2-percent of adjusted gross income limitation of section 67(a)(which was also affected by the increase in adjusted gross income). This resulted in a $914 net increase in petitioner's 1993 itemized deductions.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011