Benjamin C. Kent - Page 4

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          $20,614 for the 2000 taxable year; (5) whether petitioner is                
          entitled to a deduction for unreimbursed employee expenses of               
          $1,125 for the 1999 taxable year; (6) whether petitioner is                 
          entitled to a deduction for casualty and theft loss of $6,800 for           
          the 1999 taxable year; and (7) whether petitioner is liable for             
          accuracy-related penalties under section 6662(a) for the 1999 and           
          2000 taxable years.                                                         
               Petitioner resided in Dumfries, Virginia, at the time of               
          filing his petition.  Some of the facts have been stipulated, and           
          they are so found.  The stipulation of facts and the attached               
          exhibits are incorporated herein by this reference.  For                    
          convenience we combine our findings of fact and conclusions.                
               Petitioner filed timely Federal income tax returns for                 
          taxable years 1999 and 2000.  In each return, petitioner claimed            
          a dependency exemption deduction for his brother Bennard Kent and           
          head-of-household filing status.  Petitioner also claimed the               
          following deductions, expenses, and losses:                                 
               Deduction, Expense, or Loss         1999         2000                  
               Moving expenses               $29,500        $13,660                   
               Home mortgage interest             21,200    20,614                    
               Unreimbursed employee expenses     1,125     ---                       
               Casualty and theft loss            6,800     –--                       



               3(...continued)                                                        
          petitioner’s 1999 Federal income tax return, respondent                     
          determined that petitioner was entitled to a home mortgage                  
          interest deduction of $3,222.                                               




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