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Respondent determined deficiencies in petitioner’s 1999 and
2000 Federal income taxes and penalties as follows:
Penalty
Year Deficiency Sec. 6662(a)
1999 $14,016 $2,803.20
2000 8,005 1,601.00
After concessions,1 the issues for decision are: (1) Whether
petitioner is entitled to dependency exemption deductions for the
1999 and 2000 taxable years for his brother Bennard Kent; (2)
whether petitioner is entitled to “head of household” filing
status for the 1999 and 2000 taxable years;2 (3) whether
petitioner is entitled to deductions for moving expenses of
$29,500 for the 1999 taxable year and $13,660 for the 2000
taxable year; (4) whether petitioner is entitled to home mortgage
interest deductions of $17,9783 for the 1999 taxable year and
1 Petitioner concedes that he is not entitled to the
Schedule C, Profit or Loss From Business, loss in the amount of
$30,319 for the 2000 taxable year. Respondent concedes that
petitioner is entitled to the additional student loan interest
deduction of $48 for the 1999 taxable year. In the notice of
deficiency, respondent determined that petitioner was not
entitled to certain itemized deductions. Respondent, however,
failed to allow petitioner a standard deduction. See sec. 63(b).
Respondent concedes that, if we conclude that petitioner is not
entitled to itemized deductions for 1999 and 2000, then
petitioner would be entitled to the standard deduction for the
corresponding taxable year.
2 Respondent determined that petitioner was entitled to a
filing status of “single” for the 1999 and 2000 taxable years.
3 Petitioner claimed a home mortgage interest deduction of
$21,200 for the 1999 taxable year. After an examination of
(continued...)
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