- 2 - Respondent determined deficiencies of $758, $1,710, and $3,593 in petitioners' Federal income taxes, respectively, for 1997, 1998, and 1999, an addition to tax under section 6651(a)(1) in the amount of $86 for 1998, and penalties under section 6662(a) in the amounts of $152, $342, and $719 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 Albuquerque, New Mexico. The issues for decision are: (1) Whether petitioners are entitled to deductions for expenses incurred in a trade or business activity during 1999; (2) whether petitioners are liable for the addition to tax under section 6651(a)(1) for 1998; and (3) whether petitioners are liable for the accuracy-related penalties under section 6662(a) for each of the years in question. In addition, the Court considers the applicability of section 6673(a) to the facts of this case. For the 3 years in question, petitioners itemized their deductions on Schedule A, Itemized Deductions, of their returns. In the notice of deficiency, respondent disallowed, for each of the years in question, their itemized deductions for charitable contributions and miscellaneous deductions, including unreimbursed employee expenses and tax preparation fees. As aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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