- 3 -
denies petitioner’s claim, raised at trial, to deductions,
losses, and additional personal exemptions on a 1988 Form 1040,
U.S. Individual Income Tax Return (the 1988 return), that
petitioner filed on or about May 14, 1997, more than 2 years
after the notice was issued.
The issues for decision are whether, for the audit year,
petitioner: (1) must include in gross income $40,347, consisting
of dividends, interest, capital gains, and a distribution from a
retirement account; (2) is entitled to itemized deductions of
$11,850; (3) sustained a deductible loss of $6,724 in connection
with his law practice; (4) sustained deductible losses totaling
$29,455 in connection with the management of certain rental real
property; (5) is entitled to dependency exemptions for three
children (the dependency exemptions); (6) is liable for the
10-percent additional tax on early distributions from qualified
retirement plans under section 72(t); and (7) is liable for
additions to tax under (A) section 6651(a)(1) for failure to
timely file the 1988 return, (B) section 6653(a)(1) for
negligence, and (C) section 6654 for failure to pay estimated
income tax.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011