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documentation regarding the dependency exemption for a child and
for the following items:
Description of item 1999 2000
Short-term capital loss ($1,889) -0-
Long-term capital loss (531) -0-
Schedule C expenses 42,655 $42,567
Schedule F expenses 15,171 15,988
Real estate taxes 8,445 -0-
State/local income taxes -0- 3,922
Charitable contributions 22,636 23,127
Unreimbursed business expenses 8,532 -0-
Rate reduction credit -0- 300
On a date that does not appear in the record, petitioners sent
respondent documentation substantiating certain of the items.
Respondent allowed the losses and Schedule A deductions that
petitioners substantiated.6
On January 21, 2004, respondent issued separate notices of
deficiency for 1999 and 2000 that disallowed petitioners’
remaining capital losses, increased petitioners’ capital gains,
disallowed the remaining disputed expenses from Schedules A, C,
and F for lack of substantiation, and imposed additions to tax
for failing to file timely returns. On February 27, 2004,
petitioners filed timely petitions contesting respondent’s
determinations.
6For 1999, respondent allowed real estate taxes of $7,140
and cash contributions of $15,375. In 2000, respondent allowed a
deduction for State and local income taxes of $2,603 and the
standard deduction of $7,350. For 1999, respondent also allowed
a short-term capital loss of $469.46. However, respondent also
determined an unreported long-term capital gain in 1999 of
$9,882.80. The long-term capital gain is still in dispute.
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