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Respondent determined deficiencies of $2,927, $1,943, and
$1,470 in petitioners' Federal income taxes, respectively, for
1997, 1998, and 1999 and corresponding penalties under section
6662(a) in the amounts of $585, $389, and $294.
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 Grants, New Mexico.
At trial, petitioners conceded the deficiencies in tax. The
sole issue for decision is whether petitioners are liable for the
section 6662(a) penalty for each of the years at issue.
Petitioners were both employed during the years at issue.
Mr. Delgarito was a mechanic for an electric utility company, and
Mrs. Delgarito was an automation technologist for Intel Corp. On
their joint Federal income tax returns, petitioners reported
total income and claimed itemized deductions as follows:
1997 1998 1999
Gross income $61,788 $56,670 $54,036
Itemized deductions 21,433 20,292 17,251
In the notice of deficiency, respondent disallowed the
following itemized deductions:
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