MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined the following
deficiencies and penalties in respect of petitioner's Federal
income taxes:
Taxable Year Deficiency Sec. 6662(a) Penalty
1989 $12,284 $2,457
1990 12,251 2,450
Unless otherwise indicated, all section references are to
sections of 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.
By amended pleadings, respondent asserted an increased 1990
income tax deficiency in the amount of $88,162, and an increased
1990 penalty under section 6662(a) in the amount of $17,632. The
parties settled the increased 1990 income tax deficiency, but the
additionally asserted penalty remains disputed. Petitioner has
also claimed increased deductions for automobile mileage for both
years and for dues and subscription expenses for 1990.
After concessions, the issues for decision are:
(1) How much is petitioner entitled to deduct for business
expenses for 1989 and 1990? After concessions and additional
claims by petitioner the following amounts are in contention:
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