- 3 -
Travel2 3,553 11,493 7,906
Contract labor3 -0- 5,846 3,518
Insurance expense 2074 589 755
Miscellaneous Exp. -0- -0- 484
Self-employment -0- -0- 2,532
tax deduction
Total 4,981 23,293 16,126
3. Is petitioner liable for the addition to tax for late
filing under section 6651(a)(1) for each of the years in issue?
4. Is petitioner liable for the addition to tax for
negligence under section 6653(a)(1) for 1988?
5. Is petitioner liable for the negligence penalty under
section 6662 for 1989 and 1990?
6. Is petitioner liable for the 10-percent addition to tax
under section 72(t) for early distribution from a qualified
retirement plan in 1988.
Petitioner resided in San Francisco, California, when he
filed his petition. Some of the facts have been stipulated and
are incorporated herein by this reference. For convenience we
have divided our findings of fact and opinion into separate
parts, and in most parts, because of the confused record, have
combined our findings of fact and opinion.
2 These figures include travel expenses that petitioner deducted under
contract labor expenses.
3 These figures exclude travel expenses that petitioner deducted under
contract labor expenses.
4 The amount respondent disallowed is $1,120. The parties stipulated a
disallowance of $1,220. Accordingly, since respondent disallowed $1,120 and
petitioner concedes $913, the difference is $207.
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Last modified: May 25, 2011