Christopher Wagner - Page 3




                                        - 2 -                                         

               Respondent determined deficiencies of $3,372 and $1,765 in             
          petitioner's Federal income taxes, respectively, for 1999 and               
          2000 and corresponding penalties under section 6662(a) in the               
          amounts of $674 and $353.                                                   
               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, petitioner's                
          legal residence was Albuquerque, New Mexico.                                
               For each of the years in question, petitioner claimed                  
          itemized deductions on a Schedule A, Itemized Deductions, of his            
          Federal income tax return.  For 1999, petitioner claimed itemized           
          deductions totaling $21,337, which were all disallowed by                   
          respondent.  For 2000, petitioner deducted $14,803, all of which            
          were also disallowed by respondent.  Some of the claimed itemized           
          deductions were allowable; however, because the total of such               
          deductions was less than the allowable standard deduction under             
          section 63, respondent allowed petitioner the standard deduction            
          for both years.                                                             
               Some of the adjustments in the notice of deficiency have               
          been resolved.  On petitioner's 1999 return, he claimed an                  
          itemized deduction of $4,352 for gambling losses, which                     
          respondent disallowed for lack of substantiation.  At trial,                
          respondent conceded that the loss had been substantiated, and the           
          amount would be allowable if petitioner is otherwise entitled to            





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011