MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Judge: Respondent determined income tax deficiencies, additions to tax, and penalties with respect to petitioner's taxable years 1988, 1989, and 1990, as follows: Additions to Tax Penalties Taxable Income Tax Sec. Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1) 6661 6662(a) 1988 $5,324 $1,331 $379 $1,331 -0- 1989 17,696 4,424 -0- -0- $3,539 1990 23,701 5,925 -0- -0- 4,740 Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are: 1. Did petitioner have unreported income of $1,5241 in 1988 and $32,086 in 1990? 2. How much is petitioner entitled to deduct as Schedule C expenses? After substantial concessions by both parties, the following amounts remain in contention: Category 1988 1989 1990 Depreciation -0- $(627) $(1,003) Office expense $697 1,355 1,934 Supplies 524 4,637 -0- 1 This number is derived using the unreported income figures in the Notice of Deficiency. The numbers from the Stipulation of Facts differ by $3.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