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Respondent determined deficiencies of $5,137 and $3,080 in
petitioners' Federal income taxes, respectively, for 1999 and
2000; an addition to tax for 1999 in the amount of $35 under
section 6651(a)(1); and penalties under section 6662(a) in the
amounts of $1,027 and $616 for 1999 and 2000, respectively.
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.
The issues for decision are: (1) Whether petitioners are
entitled to itemized deductions for charitable contributions and
unreimbursed employee business expenses, and (2) whether
petitioners are liable for the accuracy-related penalties under
section 6662(a). In addition, the Court considers the
applicability of section 6673(a) to the facts of this case.2
Petitioners were both employed during the 2 years in
question. Mr. Brown (petitioner) was employed by a furniture
rental company, and Mrs. Brown was employed by the Department of
Veterans Affairs, an agency of the United States. They reported
2 Respondent determined that petitioners failed to
include in income, for 1999, $14 in interest reported by a bank
in which petitioners had an interest-bearing account.
Petitioners conceded this adjustment at trial. The sec.
6651(a)(1) addition to tax for 1999 was also conceded by
petitioners at trial.
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