Carroll R. Furnish - Page 2




                                        - 2 -                                         
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               The issues for decision are:1  (1) Whether petitioner is               
          entitled to deduct Schedule C, Profit or Loss From Business,                
          expenses in excess of the amounts allowed by respondent, (2)                
          whether petitioner is liable for an addition to tax pursuant to             
          section 6651(a)(1) for 1993, and (3) whether petitioner is liable           
          for penalties pursuant to section 6662(a) for 1993, 1994, and               
          1995.                                                                       
                                  FINDINGS OF FACT                                    
               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 he filed his            
          petition, Carroll R. Furnish resided in West Palm Beach, Florida.           
          Mr. Furnish built the house that he lived in with his two minor             
          children with “his own hands”.  During the years in issue, he               
          owed 2 years of property taxes on his home, and he “maxed out”              
          all his credit cards.                                                       
               Prior to and during the years in issue, Mr. Furnish was in             

               1  Adjustments respondent made to petitioner’s earned income           
          credit, deduction for personal exemptions, and self-employment              
          tax are computational in nature and will be resolved by our                 
          holdings herein.                                                            






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