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After settlement of some issues, the issues for decision
are: (1) Whether petitioner is entitled to deduct expenses
relating to a home office; (2) whether petitioner has adequately
substantiated claimed business expenses relating to his scrap
metal recycling business; and (3) whether petitioner is liable
for the accuracy-related penalties.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time he filed his petition, petitioner resided in Lake Worth,
Florida.
During 1990 and 1991, petitioner owned and operated as a
sole proprietorship a scrap metal recycling business. Suppliers
would deliver scrap metal to the warehouse petitioner rented for
his business, or petitioner or his employees would pick up scrap
metal from suppliers and bring it to petitioner's warehouse.
None of the scrap metal was ever brought to petitioner's
residence in which petitioner maintained an office (home office)
for the performance of administrative and management work
relating to his scrap metal recycling business.
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Last modified: May 25, 2011