- 2 -
Respondent determined deficiencies of $3,781 and $4,746 in
petitioners' Federal income taxes, respectively, for 1999 and
2000 and corresponding penalties under section 6662(a) in the
amounts of $756 and $949.
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 Albuquerque, New Mexico.
In the stipulation, the parties agreed to reduced
deficiencies of $3,697 and $4,690, respectively, for 1999 and
2000.2 Petitioners conceded their liability for the agreed
deficiencies. The sole issue for decision is whether petitioners
are liable for the section 6662(a) penalty for each of the years
1999 and 2000.
Petitioners were both employed full time during 1999 and
2000. Mr. Thornton (petitioner) was coordinator for a paramedic
program of the University of New Mexico School of Medicine. Mrs.
2 The reduced deficiencies result from respondent's
concession that petitioners were entitled to itemized deductions
for charitable contributions of $313.70 and $189.82,
respectively, for 1999 and 2000 in lieu of the corresponding
amounts of $6,260 and $7,200 claimed on their returns.
Respondent also conceded that petitioners substantiated
unreimbursed employee business expenses of $24.51 and $546.67,
respectively, for the 2 years at issue in lieu of the
corresponding amounts of $9,394 and $11,440 claimed on their
returns. Due to the limitations of sec. 67(a), the conceded
amounts for unreimbursed employee business expenses do not result
in a tax benefit to petitioners for the years at issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011