- 9 - Petitioners’ 2000 Federal Income Tax Return Petitioners filed a 2000 Federal income tax return on December 12, 2001.5 Respondent timely mailed a statutory notice of deficiency to petitioners. Petitioners timely filed a petition with this Court for a redetermination of the determined deficiency and filed an amended petition on October 7, 2004. Petitioners subsequently submitted an amended 2000 Federal income tax return (amended tax return) in connection with respondent’s Appeals Office review of the instant case. With the exception of certain disputed deductions that are described in detail below, the parties stipulate that the amended tax return accurately reflects petitioners’ tax liability for 2000. Discussion The parties dispute whether petitioners are entitled to deductions with respect to (1) the alleged abandonment of the Vernon property by petitioner’s bankruptcy estate, (2) the alleged theft of the diamond ring by Ms. Smith, (3) the alleged failure of Ms. Smith to assume the obligation for the liens on the Southampton property, and (4) the alleged failure of Ms. Smith to file a proper 1986 Federal income tax return. Deductions are a matter of legislative grace, and petitioners bear the burden of proving that they are entitled to 5Petitioners had filed a request to extend the filing due date to Oct. 15, 2001.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011