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deductions subject to the 2-percent AGI limitation. Petitioner
was unable to substantiate any of the above-described itemized
deductions in excess of the amounts allowed by respondent.
Petitioner originally claimed $3,915 for employee business
vehicle expense and $2,194 for his wife’s car and truck expenses.
Petitioner has shown entitlement to $5,498 for his employee
business vehicle expense and to $6,951 for his wife’s car and
truck expenses.
Respondent determined that for petitioner’s 1999 taxable
year, he was liable for additions to tax under sections
6651(a)(1) and 6654. Petitioner concedes that he is liable for
both additions to tax.
In a prior case, petitioner petitioned this Court seeking a
redetermination of a 1998 income tax deficiency determined by
respondent. The 1998 case was resolved by means of a settlement
entered into by petitioner and respondent on May 1, 2002. This
Court entered the parties’ stipulated decision on May 3, 2002.
The decision entered for petitioner’s 1998 taxable year resulted
in a $48,767 income tax deficiency and a $5,601 section
6651(a)(1) addition to the tax.
One of the items resolved by the 1998 decision was
respondent’s disallowance of a $5,4334 loss claimed on Schedule C
4 Petitioner originally claimed $5,779. Respondent allowed
$346 which reduced the disallowed loss to $5,433.
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