- 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011