Vittorio Kellum - Page 3

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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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