- 2 - Respondent determined a deficiency of $4,860 in petitioners’ Federal income tax for the taxable year 1997. The cover page of the notice of deficiency shows a deficiency of $14,341 for the year at issue. The $9,481 discrepancy relates to tax previously assessed because of computational errors on petitioners’ 1997 Federal tax return. See sec. 6213(b)(1). When issuing the notice of deficiency, respondent inadvertently included the tax previously assessed because of the computational errors in the amount of the deficiency. Accordingly, the amount in dispute determined in the notice of deficiency is $4,860.1 In the notice of deficiency, respondent also determined that petitioners failed to report $6,043 of alternative minimum tax (AMT). Some of the facts in this case have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time the petition was filed, petitioners lived in Woodbury, New York. In the stipulation of facts, respondent concedes that petitioners are entitled to (1) an additional deduction of $300 for State and local income taxes above the amount originally claimed on Schedule A, Itemized Deductions, and (2) a $7 foreign 1 The inconsequential error on the cover page of the notice of deficiency does not affect the validity of the notice. See Stussy v. Commissioner, T.C. Memo. 2002-257.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