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respectively, and an accuracy-related penalty under section
6662(a) in the amount of $714 for 1992.
The issues for decision are: (1) Whether Charles A. Willits
(petitioner) is entitled to deductions relating to the Sky
Shuttle activity; (2) whether petitioner Carol M. Willits (Mrs.
Willits) substantiated the expenses claimed for her day care
business for 1993;2 and (3) whether petitioners are liable for
the accuracy-related penalty under section 6662(a) for 1992.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time their
petition was filed, petitioner resided in Washington, D.C., and
Mrs. Willits resided in Huntington Beach, California.
Sky Shuttle Activity
Petitioner has degrees in civil engineering and
architecture. During the years at issue, petitioner worked for
the National Aeronautics and Space Administration (NASA) on
projects involving aviation. Before the aviation projects,
petitioner worked on the architecture of the space station.
2 In the notice of deficiency, respondent contended that
Mrs. Willits’ day care activity was not entered into for profit.
At trial respondent conceded that issue. Because of our holdings
on the issues, there will be computational adjustments for self-
employment tax (and the self-employment tax deduction) and
itemized deductions.
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