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petitioners' Federal income tax and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6661
1985 $23,877 $5,969 $5,969
After concessions, the issues for decision are: (1) Whether
petitioners are entitled to a Schedule A deduction for charitable
contributions in the amount of $1,127; (2) whether petitioner
Joan Marie Kerrigan (Mrs. Kerrigan) is entitled to Schedule C
deductions for advertising expenses of $3,974; car and truck
expenses of $783.50; commissions of $2,485.33; depreciation of
$2,644; and freight expenses of $39; (3) whether petitioner John
Edward Kerrigan (Mr. Kerrigan) is entitled to Schedule C
deductions for repairs of $3,610.55 and supplies of $6,143; (4)
whether Mrs. Kerrigan and Mr. Kerrigan are entitled to Schedule C
deductions for insurance expenses of $571 and $146, respectively;
laundry and cleaning expenses of $1,107 and $618.55,
respectively; office expenses of $3,342.15 and $2,829.89,
respectively; and travel and entertainment expenses of $16,657.12
and $7,113.69, respectively; (5) whether petitioners are liable
1(...continued)
this in their brief, and it is clear that withholding credits are
not to be taken into account in determining the amount of the
taxpayer's "deficiency". See sec. 6211(a). Respondent, on the
other hand, agrees that petitioners are entitled to a credit for
the previously withheld tax when calculating the amount of any
unpaid tax.
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