- 50 - identical adjustment in docket No. 5508-99, in order to protect the Government’s interest. Respondent concedes this adjustment in docket No. 19027-98. 4. Respondent concedes petitioner may be entitled to deduct a larger amount for charitable contributions for the taxable year, as and to the extent shown in the Rule 155 computation. 5. Respondent’s adjustments computationally eliminated petitioner’s net operating loss for 1994. In accordance with certain of respondent’s concessions and for purposes of the Rule 155 computation, respondent concedes petitioner incurred a net operating loss for 1995, in an amount at least equal to $48,872, and that it may be carried back to petitioner’s 1992 taxable year. 6. Respondent determined petitioner was liable for an accuracy-related penalty pursuant to sec. 6662(a). Respondent concedes that determination. II. Docket No. 4816-99, Joseph P. and Jean Ann Richard: A. 1994: 1. The parties previously agreed to increase and decrease taxable income to account for a Schedule A expense, Schedule C expenses and depreciation, Schedule E income and expenses, and the self- employment tax and the self-employment tax deduction. 2. Respondent made various computational changes to petitioners’ taxable income so that the limitation of itemized deductions was increased, itemized deductions were eliminated, the standard deduction was allowed, and the exemption amount under sec. 151(d)(3) was reduced. The extent to which these changes affect petitioners’ ultimate liability will be calculated in the Rule 155 computation. B. 1995: 1. The parties previously agreed to increase and decrease taxable income to account for a Schedule A expense, Schedule C expenses and depreciation, Schedule E income and expenses, and the self- employment tax and the self-employment tax deduction. 2. Respondent made various computational changes to petitioners’ taxable income so that the limitation of itemized deductions was increased, itemized deductions were eliminated, the standard deduction was allowed, and the exemption amount under sec. 151(d)(3) was reduced. The extent to which these changes affect petitioners’ ultimate liability will be calculated in the Rule 155 computation. 3. Respondent increased petitioners’ taxable incomePage: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
Last modified: May 25, 2011