- 2 - Respondent determined the following deficiencies in petitioners' Federal income taxes and penalties: Penalty Year Deficiency Sec. 6662(a) 1990 $3,161 $632 1991 6,003 943 1992 5,284 288 After concessions by the parties,2 the issues remaining for decision are: (1) Whether petitioners are entitled to a business bad debt deduction for 1989 under section 166(a) for unpaid loans to a corporation in which Reza Rezazadeh (petitioner) was an employee/shareholder and for attorney's fees incurred in attempts to collect the loan; (2) whether petitioners are entitled to deductions under section 162(a)(2) for travel expenses incurred by Connie M. Rezazadeh (Mrs. Rezazadeh) during 1991; (3) whether petitioners' deduction for 1992 under section 162(a) of inventory 2 Petitioners claimed, on their 1990 and 1991 Federal income tax returns, deductions for unreimbursed employee expenses in the amounts of $7,093.04 and $10,274.90, respectively. In the notice of deficiency, respondent disallowed $3,165 and $8,111 of the amounts claimed, respectively. In a stipulation of settled issues (stipulation), petitioners conceded the entire disallowance for 1990 and $6,585.68 of the disallowance for 1991. Accordingly, with respect to the deduction claimed for 1991, $1,525.32 of the disallowance remains at issue, which is issue number (2) above. On their 1991 return, petitioners also claimed a deduction of $466.25 for sales taxes paid on an automobile. In the notice of deficiency, respondent disallowed the deduction in its entirety. In the stipulation, petitioners conceded this adjustment.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