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Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency of $6,175 in petitioner’s
2003 Federal income tax. After a concession,1 the issue for
decision is 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. We
incorporate the stipulation of facts and attached exhibits herein
by this reference. At the time the petition was filed,
petitioner resided in Fort Washington, Maryland.
Petitioner was a staff sergeant in the National Guard and
also worked as a customs and immigration inspector for the U.S.
Immigration and Naturalization Service (INS). After a
reorganization, petitioner was employed by the Department of
Homeland Security (DHS) during tax year 2003.2 DHS stationed
petitioner at points of entry to inspect persons entering the
country. Petitioner’s regular duty location was the Baltimore
1 Respondent conceded that petitioner is not liable for
$1,178 identified in the notice of deficiency as “uncollected
FICA tax”. Respondent has failed to provide an explanation as to
this adjustment.
2 The Court notes that on Mar. 1, 2003, the Department of
Homeland Security absorbed the U.S. Immigration and
Naturalization Service (INS). Thereafter, a new organization
called U.S. Customs and Border Protection combined INS
inspectors, Border Patrol, and Customs inspectors. See 6 U.S.C.
251 (Supp. II, 2002).
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