A. Wayne and Linda D. Doudney - Page 3

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               (6) whether petitioners properly deducted charitable                   
          contributions and State and local taxes on Schedule A for 2000;             
               (7) whether petitioners properly claimed a dependency                  
          exemption for a child for 2000; and                                         
               (8) whether petitioners are liable for additions to tax                
          under section 6651(a) for 1999 and 2000.3                                   
                                     Background                                       
               Petitioners were married during 1999 and 2000.  Petitioners            
          resided in Detroit, Texas, when their petitions in these cases              
          were filed.  Unless otherwise indicated, petitioner refers to A.            
          Wayne Doudney.4                                                             
               On July 27, 2002, petitioners mailed Forms 1040X, Amended              
          U.S. Individual Income Tax Returns, for 1999 and 2000 to                    
          respondent, who received them on July 29, 2002.5  After                     
          petitioners mailed the amended returns, respondent requested                


               3Respondent also determined self-employment adjustments of             
          $306 and $4,137 for 1999 and 2000, respectively.  The adjustments           
          are computational and turn on our resolution of the issue of                
          deductibility of the Schedules C, Profit or Loss From Business,             
          and F, Profit or Loss From Farming, expenses.  Petitioners did              
          not separately challenge the adjustments, and we do not further             
          discuss them.                                                               
               4Mr. Doudney attended the trial alone, but he stated on the            
          record that Mrs. Doudney authorized him to speak on her behalf              
          during the trial in these cases.                                            
               5There is no evidence in the record to show whether                    
          petitioners filed original Forms 1040, U.S. Individual Income Tax           
          Returns, for the years in issue and, if so, when.                           





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