- 2 -
Penalty
Year Deficiency Sec. 6662
1998 $30,752 $6,150
1999 32,136 6,427
After concessions,2 the issues for decision are as follows:
(1) Whether petitioners are entitled to deduct net operating
loss carryforwards computed with respect to 1975 on their Federal
income tax returns for 1998 and 1999;
(2) whether petitioners are entitled under section 170 to
deduct charitable contributions for the years 1998 and 1999 in
excess of those already allowed by respondent; and
(3) whether petitioners are liable under section 6662(a) and
(b) for accuracy-related penalties due to negligence and
substantial understatement of income tax for 1998 and 1999.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Petitioners, who filed joint Forms 1040, U.S.
Individual Income Tax Return, for 1998 and 1999, resided in Los
Alamos, New Mexico, when their petition in this case was filed.
2In the notice of deficiency, respondent determined that
petitioners were not entitled to home mortgage interest
deductions for 1998 and 1999 in the amounts of $2,880 and $1,617,
respectively. Respondent conceded these amounts in the
stipulation of facts. Also at issue in this case are adjustments
to itemized deductions for 1998 and 1999, which are
computational. Additionally, petitioners conceded that a net
operating loss (NOL) from 1976 had been used completely in years
before the years at issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011