- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011