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7463(b), the decisions to be entered are not reviewable by any
other court, and this opinion shall not be treated as precedent
for any other case.
Respondent determined deficiencies in petitioner’s 2002 and
2003 Federal income taxes of $16,928 and $5,189, respectively,
and an addition to tax for failure to file timely a tax return
under section 6651(a)(1) of $774 for 2003. After concessions by
respondent,3 the issues remaining for decision are: (1) Whether
petitioner is entitled to deduct medical expenses of $6,966.21
claimed on her Schedule A, Itemized Deductions, for 2003; (2)
whether petitioner is entitled to deduct business expenses of
$77,267 and $32,018 claimed on her Schedules C, Profit or Loss
From Business, for 2002 and 2003, respectively; and (3) whether
petitioner is liable for an addition to tax under section
6651(a)(1) for failure to file timely a return for 2003.
2(...continued)
each year. Due to the similarity of the issues, the Court
granted respondent’s motion to consolidate for trial, briefing
and opinion on Dec. 6, 2006.
3 Respondent concedes that petitioner is entitled to deduct
Schedule A, Itemized Deductions, of $30,477 for home mortgage
interest paid during 2002, $6,149 for charitable contributions
made in 2002, and $17,264 for a casualty loss for property in
2003. Respondent also concedes that petitioner has substantiated
$6,929.79 of the $13,896 in medical expenses claimed on her 2003
return.
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