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amounts of $9,201.60 and $1,916.96, respectively. The issues for
our consideration are: (1) Whether petitioner is entitled to
itemized and Schedule C deductions in excess of those allowed or
conceded by respondent; and (2) whether petitioner and
respondent, as part of the settlement of petitioner’s 1998 tax
controversy, had agreed to allow for 1999 a $5,433 loss that had
been claimed and disallowed for 1998.
FINDINGS OF FACT2
Petitioner resided in Littleton, Colorado, when he filed his
petition with this Court. Petitioner’s 1999 joint Federal income
tax return was filed on April 4, 2003.3 During 1999, petitioner
was a sales manager and employee of Cochlear Corporation and
received a $137,604 salary. Petitioner also received interest
income of $401 in 1999.
Respondent determined a $49,703 income tax deficiency for
petitioner’s 1999 taxable year, and petitioner contested the
entire amount. Prior to trial, respondent allowed the following
itemized deductions: $7,326 for medical and dental; $1,935 for
State and local taxes; $3,119 for real estate taxes; $1,783 for
other taxes; $22,481 for home mortgage interest; $15,900 for
charitable contributions; and $13,765 for miscellaneous
2 The parties’ Stipulation of Facts is incorporated by this
reference.
3 Although a joint return was filed, Mrs. Barela is not a
party to this action.
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