Kenneth J. Barela - Page 3

                                        - 3 -                                         
          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.                           





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

Last modified: May 25, 2011