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unreimbursed employee business expenses; (3) whether, for the
years 1998 and 1999, petitioners are entitled to itemized
deductions for home mortgage interest in excess of amounts
conceded by respondent; (4) whether, for the year 1998,
petitioners are entitled to an itemized deduction for real estate
taxes in excess of an amount orally conceded by respondent at
trial; (5) whether petitioners are entitled to deductions for
expenses incurred by Mrs. Satriana during 1999 in the conduct of
a trade or business activity; and (6) whether petitioners are
liable for the accuracy-related penalties under section 6662(a).
In addition, the Court considers the applicability of section
6673(a) to the facts of this case.
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 Bernalillo, New Mexico.
Petitioners were both employed during the years at issue.
Mr. Satriana was a building inspector for the City of Rio Rancho,
New Mexico, and Mrs. Satriana was administrator for a substance
abuse prevention program for Sandoval County, New Mexico. In
addition, for the year 1999, Mrs. Satriana was engaged in a Mary
Kay Cosmetics business activity.
On their joint Federal income tax returns for the years at
issue, petitioners reported gross salary and wage income of
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