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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s 2004
Federal income tax of $3,231. After concessions,1 the issues for
decision are: (1) Whether petitioner is entitled to certain
deductions claimed on Schedule C, Profit or Loss From Business,
and (2) whether petitioner is entitled to certain deductions
claimed on Schedule A, Itemized Deductions.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Santa Rosa, California.
Petitioner was employed as a psychiatric technician during
tax year 2004, earning wage income. He also worked as a licensed
vocational nurse, for which he received income that he reported
on his Schedule C.
On his 2004 Federal income tax return, petitioner reported
wages totaling $59,580, a Schedule C business loss of $15,652,
and Schedule A itemized deductions of $48,599. Respondent issued
1 Petitioner conceded that he received a State income tax
refund in the amount of $269 and that he received $575 in wages
from Maxim Healthcare Services, Inc., during tax year 2004.
Petitioner also conceded that he is not entitled to his claimed
itemized deduction of $11,000 for legal fees related to defense
of a tax lien. At trial, respondent conceded that petitioner is
entitled to a $250 deduction for tax preparation fees.
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