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Sec. 6662(a)
Year Deficiency Accuracy-Related Penalty
1990 $3,522 $704
1991 4,383 877
1992 4,906 981
After a concession by petitioner,2 the issues for decision
are: (1) Whether respondent's determination in the notice of
deficiency was arbitrary; (2) whether petitioner has any remedy
in this Court in regard to respondent's purported misconduct in
the course of examining petitioner's returns; (3) whether
petitioner is entitled to claimed Schedule C deductions for
various expenses incurred pursuant to his activities as a free-
lance writer; (4) whether petitioner is liable for self-
employment taxes with respect to his net income earned as a free-
lance writer; and (5) whether petitioner is liable for the
accuracy-related penalty under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are
so found. The stipulated facts and attached exhibits are
incorporated herein by reference. At the time of the filing of
the petition, petitioner resided in Lodi, California.
During the years in issue, petitioner worked as an
electronics training instructor for the Department of Defense.
At that time, petitioner was also a self-employed writer,
reporting items of income and deductions on Schedules C.
2 Petitioner concedes that slot machine winnings of $1,421,
reported on Schedule C for 1991, should be recharacterized as
"other income".
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Last modified: May 25, 2011