Harald Berrey - Page 6

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          1040, U.S. Individual Income Tax Return, for the taxable year               
          1999 with a filing status of married filing jointly.  The Federal           
          income tax return for the taxable year 1999 was signed by                   
          petitioner and petitioner’s wife, Cynthia K. Berrey, on or about            
          March 31, 2004.  On his Form 1040, petitioner reported the                  
          following relevant items:                                                   
          Line                                      Amount                            
               7    Wages                         $88,904                             
               8a Taxable interest                71                                  
               9    Ordinary dividends                 89                             
               13   Capital gain                       966                            
               16a Total pensions and annuities   96,761                              
               16b Taxable amount                 96,761                              
               34   Adjusted gross income         187,214                             
               36   Itemized deductions           53,512                              
               53   Tax on IRAs,...               6,323                               
          On Schedule A, Itemized Deductions, petitioner reported the                 
          following relevant deductions and expenses:                                 
               Line                                 Amount                            
               1    Medical and dental expenses   $47,570                             
               2    Adjusted gross income1        187,214                             
               3    Multiply line 2 above by 7.5%2  14,041                            
               4    Medical expense deduction     $33,529                             
               1Amount from Form 1040, line 34.                                       
               27.5-percent limitation under sec. 213(a).                             
               As of the time of trial, petitioner’s Form 1040, which was             
          submitted to respondent’s Appeals officer, had not been accepted            
          by respondent.  Also, as of the time of trial, respondent had not           
          assessed the tax due from Ms. Berrey because, as respondent                 
          explained, “[petitioner] and * * * [Ms. Berrey] filed jointly,              






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