Peter Spuler, Jr. - Page 6

                                        - 5 -                                         
               On March 26, 2000, petitioner filed a Form 1040 for the 1998           
          taxable year (1998 return).  He filed as a “head of household”              
          and claimed an IRA deduction of $2,000 and a self-employed health           
          insurance deduction of $4,987.                                              
               On May 31, 2000, petitioner contracted Lyme disease, which             
          resulted in his receiving a doctor’s care for retinal                       
          degeneration.                                                               
               Respondent issued petitioner a notice of deficiency dated              
          August 1, 2001.  For the 1997 taxable year, respondent adjusted             
          petitioner’s filing status from “married filing joint return” to            
          “married filing separate return” and determined an addition to              
          tax of $1,468.25 under section 6651(a)(1) and a penalty of                  
          $2,212.20 under section 6662(a).4  For the 1998 taxable year,               
          respondent determined an addition to tax of $5,341.75 under                 








               4  Respondent also made other adjustments to the 1997                  
          return.  Some of them are computational or result from                      
          respondent’s proposed adjustment in petitioner’s filing status.             
          They include changes to the amount of (1) alternative minimum               
          tax, (2) exemptions, (3) itemized deductions, and (4) wage                  
          income.  The remaining adjustments, as indicated, have been                 
          resolved by mutual concession.  They involve the following:  (1)            
          Inclusion of unreported capital gain of $5,981; (2) disallowance            
          of a self-employed health insurance deduction of $4,866; and (3)            
          disallowance of a deduction for Keogh and self-employed SEP and             
          SIMPLE plans of $30,000.                                                    




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011