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1986
1. For taxable year 1986, petitioners are
entitled to total Schedule E expenses in the amount of
$212,906.44.
2. For taxable year 1986, petitioners are not
entitled to a Schedule A medical expense deduction.
3. For taxable year 1986, petitioners are
entitled to a Schedule A mortgage interest expense
deduction in the amount of $5,218.00.
4. For taxable year 1986, petitioners are not
entitled to a Schedule A charitable contribution
deduction.
5. For taxable year 1986, petitioners are subject
to an addition to tax pursuant to I.R.C. Section
6651(a).
6. For taxable year 1986, petitioners are subject
to an addition to tax pursuant to I.R.C. Section
6653(a)(1)(A) for negligence.
7. For taxable year 1986, petitioners are subject
to an addition to tax pursuant to I.R.C. Section
6653(a)(1)(B) for negligence.
8. For taxable year 1986, petitioners are subject
to an addition to tax pursuant to I.R.C. Section 6654
for failure to pay estimated taxes.
* * * * * * *
For All Years (1986, 1987, 1988, 1989, 1990, and 1991)
47. It is further stipulated that interest will
be assessed as provided by law on any deficiencies due
from the petitioners.
48. This STIPULATION OF SETTLED ISSUES resolves
all of the issues before the Court.
Based on the stipulation, respondent prepared a decision in
each of these consolidated cases. For the 1986 taxable year,
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