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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
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