- 3 - (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 ChristPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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