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On January 23, 2003, petitioner timely filed a petition with
the Court challenging the determined deficiency stating: “Expense
for the Production of Income”.3 Thereafter, petitioner submitted
to respondent’s Appeals Office on June 4, 2003, a revised Form
1040 for 2000 (revised Form 1040). Respondent did not process
the revised Form 1040 as an amended return. The revised Form
1040 reflected in pertinent part as follows:
Line 7. Wages, salaries, tips, etc. * * * $51,824
Line 8a. Taxable interest. * * * 54
Line 12. Business income or (loss). * * * (4,207)
Line 17. Rental real estate * * * (12,500)
Line 22. * * * total income. 35,171
Line 36. * * *itemized deductions * * * 10,314
Line 39. Taxable income. * * * 22,057
Line 40. Tax 3,331
Line 58. Federal income tax withheld * * *7,940
Line 66. * * * This is the amount you overpaid.4,609
Petitioner attached to the revised Form 1040, inter alia, the
following schedules and forms that are pertinent to the issues in
this case: Schedule A, Itemized Deductions; Schedule C, Profit
or Loss from Business; Schedule E, Supplemental Income and Loss;
and Form 4684, Casualties and Thefts.
On Schedule A, petitioner claimed total itemized deductions
of $10,314, which amount included the following: State and local
income tax of $2,664; real estate tax of $133; personal property
tax of $234; and a casualty or theft loss of $7,283 as calculated
3 We note, however, that petitioner did not claim any
deductions on his Form 1040, U.S. Individual Income Tax Return.
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