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Year Deficiency Accuracy-Related Penalty
1995 $95,369 $17,272.40
1996 65,748 8,194.60
1997 13,943 2,788.60
The issues remaining for decision2 are:
(1) Are petitioners entitled to deduct a claimed casualty
loss for 1997? We hold that they are not.
(2) Did petitioners understate the amount of long-term
capital gain that they realized for 1995 on the sale of certain
property? We hold that they did.
(3) Are petitioners entitled to deduct for each of the
years 1996 and 1997 certain claimed rental expenses with respect
to their residence? We hold that they are not.
(4) Are petitioners entitled to deduct for 1996 mortgage
interest in excess of the amount conceded by respondent? We hold
that they are not.
(5) Are petitioners liable for each of the years at issue
for the accuracy-related penalty under section 6662(a)? We hold
that they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
1(...continued)
the Tax Court Rules of Practice and Procedure.
2Computational or correlative issues also remain, resolution
of which flows automatically from the concessions of respondent
and our resolution of the determinations in the notice of defi-
ciency (notice) that we address herein.
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