Michael White - Page 3

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               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.                                                              

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