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After concessions, the issues for decision are:
(1) Whether, pursuant to section 162(a), petitioners are entitled
to deductions in the amounts claimed for unreimbursed employment
expenses; (2) whether, pursuant to section 212, petitioners are
entitled to deductions in the amounts claimed for investment
expenses; (3) whether, pursuant to section 170, petitioners are
entitled to deductions in the amounts claimed for charitable
contributions; (4) whether, pursuant to section 212, petitioners
are entitled to a deduction in the amount claimed for expenses
attributable to real property held for the production of income;
(5) whether, pursuant to section 280A(c)(1), petitioners are
entitled to deductions for expenses attributable to an office in
the home; and (6) whether, pursuant to section 6662(a),
petitioners are liable for penalties due to negligence or
disregard of rules or regulations. Unless otherwise indicated,
all section references are to the Internal Revenue Code in effect
for the years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
At the time of the filing of the petition, petitioners
resided in Elmhurst, Illinois. Aziz A. Tokh (petitioner) is an
architect at Northeast Illinois Railroad Corporation (NIRC), and
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