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(3) whether petitioners are entitled to deduct on their
Schedule C for the taxable years 1988, 1989, and 1990, various
expenses in excess of those allowed by respondent;
(4) whether petitioners are liable for the addition to tax
for negligence under section 6653(a)(1) for 1988;
(5) whether petitioners are liable for an accuracy-related
penalty for negligence under section 6662(a) for 1989 and 1990;
and
(6) whether petitioners are liable for an addition to tax
for late filing under section 6651(a)(1) for 1990.
For simplicity and clarity, we will first set forth the
relevant background facts and general legal principles; we will
then combine additional findings of fact and opinion for each
issue.
Background Facts
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Dothan, Alabama, at the time that
their petition was filed with the Court.
Petitioner Wayne Hairston (petitioner) received both a
bachelor's degree in psychology and a graduate degree in
Christian counseling from Liberty University. Petitioner has
also completed undergraduate religion courses and graduate
theology courses. In addition to his formal education,
petitioner is an ordained minister. Petitioner was ordained by
the Body of Christ Church on May 17, 1987. The Body of Christ
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