Steven J. and Terry L. Namyst - Page 5

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          between expense reimbursements and payments for IMC’s purchase of           
          petitioner’s old tools.                                                     
               Respondent determined deficiencies for each of petitioners’            
          taxable years 1996, 1997, 1998, and 1999.  In a notice of                   
          deficiency dated August 28, 2003, respondent adjusted                       
          petitioners’ income for each year to include the amounts of the             
          checks from IMC.  As a result of respondent’s adjustments to                
          petitioners’ gross income, petitioners were no longer entitled to           
          the earned income credits claimed on their returns for 1996,                
          1997, 1998, and 1999.  The parties stipulated that petitioners              
          are entitled to the child tax credit for 1998 and 1999.                     
          Respondent also conceded that petitioners were entitled to                  
          miscellaneous itemized deductions, limited under section 67(a) to           
          the extent the expenses exceeded 2 percent of petitioners’                  
          adjusted gross income, for the expenses petitioner paid on behalf           
          of IMC in each year.  On brief, respondent conceded an additional           
          $3,181.82 of petitioners’ expenses for 1996.  The only expenses             
          listed by petitioner that were not allowed as miscellaneous                 
          itemized deductions by respondent in either the notice of                   
          deficiency or on brief were those made by petitioner before March           
          1996.  Respondent treated the amounts petitioners received from             
          IMC in exchange for petitioner’s old tools as wage income.                  
          Respondent also determined that petitioners were liable for an              








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