Sonja and David Brown - Page 3




                                        - 2 -                                         

               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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