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Item Petitioner Mr. Capehart Total
Income
Wages $20,146.00 $31,925.00 $52,071
Interest 236.50 236.50 473
Dividends 67.50 67.50 135
State income tax 186.50 186.50 373
Capital gains 95.00 95.00 190
Pension -0- 12,426.00 12,426
Gambling income 1,229.00 1,229.00 2,458
Adjustments to income
IRA deductions (1,200.00) (1,200.00) (2,400)
Adjusted gross income 20,760.50 44,965.50 65,726
Itemized deduction
State income tax -0- 442.00 442
Real estate taxes 453.50 453.50 907
Personal property 252.00 252.00 504
Mortgage interest 2,082.00 2,082.00 4,164
Charitable 90.00 90.00 180
Gambling loss 1,229.00 1,229.00 2,458
Exemption amount 2,450.00 2,450.00 4,900
Total deductions 6,556.50 6,998.50 13,555
Taxable income 14,204.00 37,967.00 52,171
In accordance with section 6015(d) and the applicable
regulations, petitioner’s erroneous items ($21,282.50) are first
allocated to petitioner to the extent of the $14,204 of income
reported on the joint return that would have been allocated to
her had she filed a separate return. The $7,078.50 excess of
petitioner’s erroneous items over her share of the income
reported on the joint return is then allocated to Mr. Capehart.
3. Proportionate Allocation of Deficiency
Pursuant to section 6015(d)(1), the portion of the
deficiency allocable to petitioner is the amount that bears the
same ratio to the deficiency as the net amount of erroneous items
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