Keith F. Marason - Page 2

                       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.




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