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FINDINGS OF FACT
Petitioner resided in Toledo, Ohio, at the time the petition
in this case was filed.
Petitioner timely filed his 1999 Federal income tax return.
Attached to the return was a Form W-2, Wage and Tax Statement,
from "Four-A Electric, Inc." reporting wages to petitioner of
$54,819. Petitioner reported the amount of his wages on line 7
of the return. On Schedule A, Itemized Deductions, of his
return, petitioner claimed deductions for State and local taxes
of $4,999, and charitable contributions of $100. He also claimed
on Schedule A miscellaneous itemized deductions for unreimbursed
employee expenses of $39,224, after reduction for the 2-percent
floor of section 67.1
From adjusted gross income of $55,207, petitioner deducted
total itemized deductions of $44,323, and a personal exemption of
$2,750, to arrive at taxable income of $8,134 on which he
computed a tax due of $1,219. As petitioner had total
withholding credits of $6,197, he claimed an overpayment of
$4,978. Petitioner did not attach Form 6251, Alternative Minimum
Tax-Individuals, to his 1999 income tax return, or report any
liability for the alternative minimum tax on line 51 of Form
1040, U.S. Individual Income Tax Return.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
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