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Respondent determined a deficiency in petitioner’s 1997
Federal income tax of $5,476, plus additions to tax. After
concessions by respondent, the remaining issues for decision are:
(1) Whether certain payments received by petitioner in 1997 are
excludable from gross income under section 104(a);
(2) whether petitioner is entitled to an additional charitable
contributions deduction pursuant to section 170 that was not
otherwise conceded by respondent; (3) whether petitioner is
entitled to a casualty loss deduction under section 165 stemming
from a 1997 automobile accident; (4) whether petitioner is
entitled to deduct, under section 162 or 183, various expenses
related to his insurance activity; and (5) whether petitioner is
liable for additions to tax for failure to file a timely tax
return under section 6651(a)(1) and for failure to make estimated
tax payments under section 6654(a).1
Some of the facts have been stipulated, and they are so
found. The stipulation of facts, supplemental stipulation of
facts, and the attached exhibits are incorporated by this
1 Respondent conceded prior to trial that petitioner is
entitled to the following itemized deductions: (1) Medical
expenses of $257.74; (2) personal property taxes of $1,450.11;
(3) charitable contributions of $450; (4) unreimbursed employee
business expenses of $436.75; (5) investment expenses of $513.63;
and (6) legal expenses of $1,311.25. Petitioner is also entitled
to a deduction for home mortgage interest paid of $6,809, as
reported by Temple-Island Mortgage.
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Last modified: May 25, 2011