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tuition and fees deduction under section 222 for the 2002 taxable
year;2
(5) whether petitioner may deduct moving expenses for the
2001 and 2002 taxable years;
(6) whether petitioner is liable for additions to tax under
section 6651(a)(1) in the amounts specified above for the 5
taxable years at issue;
(7) whether petitioner is liable for an addition to tax
under section 6654(a) in the amount of $519.15 for the 2001
taxable year because he failed to pay estimated income tax; and
(8) whether petitioner is liable for a penalty under section
6673(a)(1).
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts and accompanying exhibits are hereby incorporated by
reference into our findings. Some of the facts have been deemed
established pursuant to Rule 90(c) and the Court’s order under
Rule 91(f) dated November 28, 2006. At the time he filed his
petition, petitioner resided in Albuquerque, New Mexico.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended and in effect for
the taxable years at issue. The Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: March 27, 2008