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under section 6662(a). Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
FINDINGS OF FACT
Petitioners resided in Austin, Texas, at the time that they
filed their petition. During 2002, petitioner Kelvin Jackson
(Mr. Jackson) was a driver for United Parcel Service (UPS), and
petitioner Arlene Jackson (Ms. Jackson) was a self-employed
writer. On their Form 1040, U.S. Individual Income Tax Return,
for 2002, among other things no longer in dispute, petitioners
claimed on Schedule A, Itemized Deductions, the following:
Medical and dental expenses $4,673
Home mortgage interest and points 14,466
Gifts to charity by cash or check 3,600
Noncash gifts to charity 500
Unreimbursed employee expenses
(small tools) 350
On Schedule C, Profit or Loss From Business, for Ms. Jackson’s
business as a writer, petitioners claimed a total of $30,878 in
business expenses. In addition to other items not now in
dispute, petitioners claimed a $706 mortgage interest deduction
on this Schedule C.
Prior to trial, respondent conceded petitioners’ entitlement
to various items that had been claimed on their return and
disallowed in the notice of deficiency, including $4,673 of
medical and dental expenses, subject to the 7.5-percent floor
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