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Respondent determined deficiencies of $1,508, $1,163, and
$1,102 in petitioners' Federal income taxes, respectively, for
1997, 1998, and 1999 and corresponding penalties under section
6662(a) in the amounts of $302, $233, and $220.
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 McIntosh, New Mexico.
For each of the years in question, petitioners claimed
itemized deductions on a Schedule A, Itemized Deductions. In the
notice of deficiency, respondent disallowed all the amounts
claimed as deductions for each of the years at issue for
charitable contributions and miscellaneous itemized deductions,
the latter consisting of unreimbursed employee business expenses.
Other itemized deductions claimed by petitioners, although
substantiated, were less than the allowable standard deduction
under section 63(c); consequently, respondent allowed petitioners
the standard deduction for each of the 3 years at issue.
In the stipulation, petitioners conceded the deficiencies,
challenging only the penalties under section 6662(a). In
addition to considering that issue, the Court also considers the
applicability of section 6673(a) to the facts of this case.
Petitioners were both employed during 1997 and 1998;
however, petitioner Michelle Nolen was not employed during 1999.
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