- 2 -
penalty under section 6662(a) and (b)(1). After concessions,2
the issues remaining for decision are:
(1) Whether petitioner received income during 1999. We hold
that petitioner received income in 1999 and consequently is
liable for Federal income taxes;
(2) whether petitioner is entitled to an additional personal
exemption for his spouse under section 151(b). We hold that
petitioner is not entitled to an additional personal exemption
for his wife because she had income during 1999;
(3) whether petitioner is entitled to deductions for
charitable contributions, mortgage interest, and real property
taxes. We hold that petitioner cannot deduct his claimed
charitable contributions, but hold that petitioner can deduct the
portion, as so found, of mortgage interest and real property
taxes he paid in 1999; and
(4) whether petitioner is liable for the addition to tax for
failing to file a return under section 6651(a)(1) and for the
accuracy-related penalty under section 6662(a) and (b)(1). We
hold that petitioner is liable for the addition to tax under
section 6651(a), but hold that petitioner is not liable for the
2 The parties stipulated at trial that petitioner did not
receive wages from Sunshine Cos. or River Branch Corp. although
the notice of deficiency included wages from each.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011