- 2 - Respondent determined deficiencies of $3,983 and $7,182 in petitioners' Federal income taxes, respectively, for 1998 and 1999 and corresponding penalties under section 6662(a) in the amounts of $797 and $1,436. Some of the facts were stipulated, and those facts, with the annexed exhibits, are so found and are incorporated herein by reference. At the time the petition was filed, petitioners' legal residence was Albuquerque, New Mexico. For each of the years in question, petitioners claimed itemized deductions on a Schedule A, Itemized Deductions, of their Federal income tax return. For 1998, petitioners claimed itemized deductions totaling $19,380, which were totally disallowed by respondent. For 1999, petitioners deducted $36,214, of which $25,655 was disallowed by respondent. Petitioners were allowed itemized deductions for 1999, since the total of their other claimed and allowed deductions exceeded the standard deduction under section 63(c); however, for 1998, petitioners were allowed the standard deduction in lieu of itemized deductions. For the 2 years at issue, the disallowed deductions consisted of charitable contributions, job expenses, and other miscellaneous deductions. In addition, for 1998, respondent disallowed a dependency exemption deduction and disallowed itemized deductions, for that year, of $894 for taxes and $2,743 for interest. At trial, respondent conceded thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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