Louise E. Nagel and Gary B. Nagel, (2011)

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Louise E. Nagel and Gary B. Nagel, (2011)

T.C. Memo. 2011-184

UNITED STATES TAX COURT LOUISE E. NAGEL AND GARY B. NAGEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 30645-08. Filed August 2, 2011.

R determined deficiencies in Federal income taxes and additions to tax pursuant to sec. 6651(a)(1), I.R.C., for Ps' 2004 and 2006 tax years. After concessions, the issues for decision are: (1) Whether Ps are entitled to deduct as a theft loss for their 2004 or 2006 tax year expenses relating to the foreclosure of the mortgage on their then residence; (2) whether Ps are entitled to deduct as a theft loss for their 2004 and 2006 tax years expenses relating to wage garnishments; and (3) whether Ps are liable for sec. 6651(a)(1), I.R.C., additions to tax for their 2004 and 2006 tax years.

Held: Ps are not entitled to deduct expenses relating to the foreclosure of the mortgage on their then residence for their 2004 or 2006 tax year. Held, further, Ps are not entitled to deduct expenses relating to wage garnishments for their 2004 and 2006 tax years. Held, further, Ps are liable for additions to tax under sec. 6651(a)(1), I.R.C., for their 2004 and ...

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