Patrick F. Philippi - Page 6

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          Minnesota Department of Revenue regarding a tax lien for his                
          taxable year 1996, (3) petitioner’s 1996 Federal income tax                 
          return, (4) a letter from the Internal Revenue Service responding           
          to an inquiry of petitioner, in which the Internal Revenue                  
          Service informed petitioner that it had no record of a lien                 
          “being filed for personal taxes for tax years 1988-1999”, and               
          (5) a transcript of the court proceedings of the felony sentenc-            
          ing of petitioner in the District Court, Tenth Judicial District,           
          of the State of Minnesota.  None of the exhibits on which peti-             
          tioner relies supports his position in this case with respect to            
          the claimed deductions at issue.                                            
               Based upon our examination of the entire record before us,             
          we find that petitioner has failed to carry his burden of estab-            
          lishing that he is entitled (1) for the taxable year 2000 to                
          Schedule A deductions in excess of those allowed by respondent,             
          (2) for the taxable years 1999 and 2000 to Schedule C deductions            
          claimed in his 1999 return and his 2000 return, respectively, and           
          (3) for the taxable year 1999 or the taxable year 2000 to a                 
          claimed rental loss deduction.                                              
               We have considered all of the contentions and arguments of             
          petitioner that are not discussed herein, and we find them to be            
          without merit and/or irrelevant.                                            









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