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Respondent determined deficiencies of $2,707, $3,318, and
$1,058 in petitioners' Federal income taxes, respectively, for
1997, 1998, and 1999, and penalties under section 6662(a) in the
amounts of $541, $664, and $212 for 1997, 1998, and 1999,
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 Rio Rancho, New Mexico.
The issues for decision are: (1) Whether petitioners are
entitled to itemized deductions for charitable contributions and
unreimbursed employee business expenses for the 3 years at issue,
and, additionally, for a deduction for medical expenses for 1997,
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.
Petitioners were both employed during the 3 years in
question. Mr. Chambers was a technician for GSA Albuquerque
Federal Building during 1997 and 1998. He also worked for
Timberland Services, Inc., for a portion of 1997 and for
Presbyterian Healthcare Service in 1998. During 1999, he worked
only for Presbyterian Healthcare Service. Mrs. Chambers was a
document controller for Intel Corp. during 1997 and for a portion
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