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Respondent determined deficiencies in petitioners’ Federal
income taxes and penalties for 2003 and 2004 as follows:
Year Deficiency Penalty, Sec. 6662(a)
2003 $7,684 $1,536.80
2004 4,451 890.20
After concessions by petitioners, the sole remaining issue for
decision is whether petitioners are entitled to a deduction under
section 179 of $24,000 for 2003. Unless otherwise indicated, all
section references are to the Internal Revenue Code in effect for
the years in issue.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Atlanta, Georgia, at the time that they
filed this petition.
During 2003, petitioner husband was employed as a computer
analyst, and petitioner wife was employed as a school nurse.
Petitioners also had a janitorial cleaning business during that
year. Petitioners’ Federal income tax returns for 2003 and 2004
were prepared by Joseph L. Wilson (Wilson).
Respondent disallowed various deductions claimed by
petitioners on their 2003 and 2004 Federal income tax returns.
The only adjustment that petitioners contested was the
disallowance of a $24,000 expense deduction claimed on Form 2106,
Employee Business Expenses, for 2003. Petitioners’ Form 2106 for
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Last modified: November 10, 2007