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Respondent determined a deficiency of $5,761 in petitioner’s
Federal income tax for 2002 and an addition to tax of $1,326.75
under section 6651(a)(1). Unless otherwise indicated, all
section references are to the Internal Revenue Code in effect for
the year in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
The issues for decision are whether petitioner is entitled
to any deductions disallowed in the statutory notice of
deficiency and whether petitioner is entitled to relief under
section 6015.
Background
Certain facts have been deemed stipulated pursuant to
Rule 91(f). Petitioner resided in Georgia at the time that her
petition was filed. On March 24, 2004, she filed a joint Federal
income tax return for 2002 on a Form 1040, U.S. Individual Income
Tax Return, with Xavier White. Petitioner filed a Complaint for
Divorce from Xavier White on November 28, 2005, and the Final
Judgment and Decree was entered on January 17, 2006.
After reviewing the Form 1040 filed by petitioner and her
former husband, respondent disallowed the following claimed
itemized deductions:
(a) $17,028 of medical and dental expenses;
(b) $8,471 of gifts to charity; and
(c) Job expenses and other miscellaneous deductions
comprised of:
(1) $16,649 of unreimbursed vehicle mileage
expense;
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