- 2 -
Respondent determined deficiencies of $5,561 and $5,818 in
petitioners' Federal income taxes, respectively, for 1998 and
1999 and corresponding penalties under section 6662(a) in the
amounts of $1,112 and $1,164.
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 Jemez Pueblo, New Mexico.
For each of the years in question, petitioners claimed
itemized deductions on a Schedule A, Itemized Deductions, of
their Federal income tax return. For 1998, petitioners claimed
itemized deductions totaling $28,346, of which $19,861 was
disallowed by respondent. For 1999, petitioners deducted
$28,263, of which $20,757 was disallowed by respondent.
Petitioners, nevertheless, were allowed itemized deductions for
both years, since the total of their other claimed and allowed
deductions exceeded the standard deduction under section 63(c).
For the 2 years at issue, the disallowed deductions consisted of
charitable contributions, job expenses, and other miscellaneous
deductions.
The issues for decision are: (1) Whether petitioners are
entitled to the disallowed itemized deductions for charitable
contributions, job expenses, and other miscellaneous deductions,
and (2) whether petitioners are liable for the penalties under
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011