Michael A. and Teresa F. Albach - Page 3




                                        - 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 the                 





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