- 2 - taxable year in issue, and all Rule numbers refer to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PAJAK, Special Trial Judge: Respondent determined a deficiency in petitioners' 1988 Federal income tax in the amount of $9,748, and an addition to tax under section 6653(a)(1) in the amount of $487. This Court must decide: (1) Whether petitioners have substantiated deductions claimed on the Schedule C attached to their 1988 Federal income tax return in excess of the amounts allowed by respondent; and (2) whether petitioners are liable for an addition to tax for negligence under section 6653(a)(1). Some of the facts in the case have been stipulated and are so found. Petitioners resided in Liverpool, New York, at the time they filed their petition. For clarity and convenience, the findings of fact and opinion have been combined. During 1988, petitioner Joseph D. Wilkins (petitioner) operated a sole proprietorship known as Golden Rule Furniture, which dealt in wholesale furniture. Petitioner claimed there was a "big loss" in 1988 because Golden Rule Furniture was a "part- time job". Petitioner operated the business out of his house, out of his basement, and out of his garage. He also testifiedPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011