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After concessions, the issues for decision are: (1) Whether
petitioner's correct filing status for the taxable year 1989 was
"single" or "married filing separate"; (2) whether petitioner's
Schedule C gross receipts were understated by $3,600; (3) whether
petitioner is entitled to certain Schedule C deductions for the
taxable year 1989; (4) whether petitioner is entitled to a
charitable contribution deduction in the amount of $924; and (5)
whether petitioner is liable for the accuracy-related penalty for
negligence or substantial understatement of income tax pursuant
to section 6662(a) for the taxable year 1989.
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts, and
attached exhibits are incorporated herein by this reference.
Background
At the time petitioner filed her petition in this case, she
resided in Roseville, California.
Petitioner is a certified vocational rehabilitation
counselor. During 1989, petitioner operated Shackelford
Vocational Rehabilitation Services as a sole proprietorship
(hereinafter referred to as petitioner's business). Petitioner
maintained a business checking account with Wells Fargo Bank in
Marysville, California. She used the deposits to this account to
determine her Schedule C gross receipts for tax purposes.
As a vocational rehabilitation counselor, petitioner worked
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