Nathan Jaramillo and Davina Metzgar - Page 3




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               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 a              





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