- 2 - Respondent determined deficiencies of $2,942 and $3,654 in petitioner's Federal income taxes, respectively, for 1998 and 1999 and corresponding penalties under section 6662(a) in the amounts of $588 and $731. 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 Edgewood, 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. In the notice of deficiency, respondent disallowed all the amounts claimed as deductions for each of the years at issue for charitable contributions and miscellaneous itemized deductions, the latter consisting of unreimbursed employee business expenses. For the year 1998, other itemized deductions claimed by petitioner, although substantiated, were less than the allowable standard deduction under section 63(c); consequently, respondent allowed petitioner the standard deduction for that year. At trial, respondent conceded that petitioner substantiated an itemized deduction for home mortgage interest for 1999, and, as a result of that concession, petitioner is entitled to itemized deductions for 1999 in lieu of the standard deduction determined in the notice of deficiency.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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