Elliot Virgil Wilkerson - Page 3

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               Respondent determined a deficiency in petitioner’s Federal             
          income tax of $11,493 for the taxable year 2000, as well as an              
          accuracy-related penalty under section 6662(a) in the amount of             
          $711.                                                                       
               After petitioner’s concessions,2 the remaining issues for              
          decision are:                                                               
               (1)  Whether petitioner received unreported business and               
          rental income.  We hold that he did to the extent provided                  
          herein.                                                                     
               (2)  Whether petitioner is entitled to claim various                   
          Schedule C and Schedule E deductions.  We hold that he is not.              
               (3)  Whether petitioner is entitled to claim various                   
          itemized deductions for state and local taxes.  We hold that he             
          is not.                                                                     
               (4)  Whether petitioner is entitled to claim a personal                
          casualty or theft loss of $7,283.  We hold that he is not.                  
               (5)  Whether petitioner is liable for the accuracy-related             
          penalty under section 6662(a).  We hold that he is.                         






               2  At trial and in the stipulation of facts, petitioner                
          conceded the adjustments in the notice of deficiency;                       
          specifically, that he received unreported income in the following           
          amounts: (1) Wages of $51,824; (2) interest of $54; and (3)                 
          rental income in the amounts of $2,380 and $642, for a total of             
          $3,022.                                                                     




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