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the mortgage loan being replaced, and various closing costs
totaling $948.95, described on the settlement sheet as follows:
Loan origination fee 0.218% $167.00
Appraisal fee 250.00
Flood 17.00
Attorney's fees 391.00
Recording fees 32.00
State tax/stamps 87.95
Computer filing fee 4.00
On Schedule A of the 2000 Form 1040, petitioner claimed an
itemized deduction for "closing costs on house" of $1,367.73, a
figure which closely approximates the $1,371.73 total of the
foregoing payments.4
Notice of Deficiency
After the 2000 Form 1040 was referred to three units of
respondent, a notice of deficiency was issued to petitioner for
the 2000 taxable year in which it was determined that petitioner
had failed to file a return and had taxable income of $39,831,5
resulting in a deficiency of $8,301 and additions to tax under
section 6651(a)(1) for failure to file and section 6654 for
failure to pay estimated tax. Petitioner timely filed a petition
for redetermination.
4 The $4 discrepancy is not explained in the record.
5 This taxable income figure represented gross income of
$46,306 from pension distributions, Social Security benefits and
gambling winnings, less the standard deduction and a personal
exemption.
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Last modified: May 25, 2011