Lindley Anthony Swanston - Page 2

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               The issues for decision are:  (1) Whether petitioner is                
          entitled, under section 162(a), to cost of goods sold and                   
          deductions for trade or business expenses incurred in connection            
          with a book-selling activity, and (2) whether petitioner is                 
          liable for the addition to tax under section 6651(a)(1).                    
               Some of the facts were stipulated.  Those facts, with the              
          exhibits offered in connection therewith, are so found and are              
          incorporated herein by reference.  Petitioner was a resident of             
          Silver Spring, Maryland, at the time the petition was filed.                
               During 1988, petitioner sold books, an activity he began               
          sometime during 1987 following a career as a life insurance                 
          agent.  Petitioner sold his books at conventions and seminars in            
          various parts of the United States.  Most of the places where               
          petitioner sold his books were religious gatherings or                      
          conventions, and most of his books were of a religious nature;              
          however, sometime during 1988, he began selling secular books               
          together with the religious books.  Petitioner generally rented             
          one or more booths or exhibit spaces at each convention, where he           
          displayed and sold his books.  Petitioner did not have a fixed              
          retail place of business.  When he was not attending a                      
          convention, he stored his book inventory at home.  He did not               
          conduct any sales activity at home.  Petitioner did not employ              
          anyone, but, frequently, his wife and daughter accompanied him              
          and assisted in his sales.                                                  





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