- 4 - Federal income tax returns. On the 1997 return, petitioners claimed itemized deductions totaling $21,622, for 1998 the itemized deductions totaled $24,811, and for 1999 the deductions totaled $14,250. In the notice of deficiency, respondent disallowed $13,968, $15,910, and $14,250, respectively, of the itemized deductions for the 3 years in question.3 At the time petitioners met with Mr. Beltran for preparation of their 1997 return, they were aware and knew that documentary information was necessary to substantiate the income and expenses reported and claimed on their returns. They presented such information to Mr. Beltran; however, as Mrs. Chambers testified at trial: "We handed Robin everything we had and he handed it back to us, stating that he didn't need to see what we had." The only adjustments in the notice of deficiency relate to petitioners' itemized deductions for the 3 years in question. On their 1997 return, petitioners claimed an itemized deduction of $5,842 for medical and dental expenses, prior to application of the 7.5-percent limitation under section 213(a). Respondent disallowed the amount claimed for lack of substantiation. 3 For 1997 and 1998, other claimed itemized deductions were not adjusted, and the total of such allowed deductions exceeded the standard deduction under sec. 63(c). Petitioners, therefore, were allowed itemized deductions for these 2 years in the notice of deficiency. For 1999, petitioners were allowed the standard deduction under sec. 63(c).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011