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Addition to tax
Year Deficiency sec. 6651(a)(1)
1999 $23,553 $1,040.75
2000 32,153 6,190.00
Petitioners filed a separate petition for each year contesting
respondent’s determinations. Because these cases present common
issues of fact and law, they were consolidated for trial,
briefing, and opinion pursuant to Rule 141(a).
After concessions,2 the issues for decision are:
(1) Whether petitioners properly deducted capital losses on
Schedule D, Capital Gains and Losses, for 1999;
(2) whether respondent properly determined that petitioners
had unreported capital gain income for 1999;
(3) whether petitioners properly deducted various expenses
on Schedule C, Profit or Loss From Business, for 1999 and 2000;
(4) whether petitioners properly deducted expenses on
Schedule F, Profit or Loss From Farming, for 1999 and 2000;
(5) whether petitioners properly deducted real estate taxes,
charitable contributions, and unreimbursed business expenses on
Schedule A, Itemized Deductions, for 1999;
1(...continued)
are to the Tax Court Rules of Practice and Procedure.
2In the notice of deficiency for 2000, respondent included
$640 of unreported capital gain income in petitioners’ tax
determination. At trial, petitioner A. Wayne Doudney conceded
that this was taxable income to him and his wife.
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Last modified: May 25, 2011