- 2 - 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".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011