- 2 - stipulated, the only remaining issue for trial is whether petitioner is liable for an accuracy-related penalty under section 6662. The parties filed a stipulation of settled issues showing that petitioner failed to report a State tax refund of $235; interest income of $736; and net gambling income of $27,407. The parties also stipulated agreed adjustments to Schedule C of petitioner's income tax return as follows: Description Per return Agreed adjustment to return Agreed total Gross Receipts $23,960 $80,902 $104,862 Less: Cost of 25,881 47,143 73,024 Sales Gross Income (1,921) 33,759 31,838 Petitioner had deducted Schedule C expenses of $17,237. The parties agree to an adjustment of $6,576, or total Schedule C expenses in the amount of $10,661. These agreements result in net Schedule C income in the amount of $21,177 (i.e., $31,838-$10,661), as opposed to a loss of $19,158 claimed on the return. There will also be an automatic adjustment to self-employment tax, which will be computed mathematically. Some of the facts have been stipulated and are so found. The stipulation and attached exhibits are incorporated herein by this reference. At the time of filing the petition herein, petitioner resided in San Jose, California. Petitioner was born May 5, 1957, in Tabriz, Iran. He attended but did not complete college in the United States and became a permanent resident in 1984. Since that time he has been employed as an engineer. In mid-1988 petitioner started a business called ESTI Memory International (EMI). Petitioner's father died in 1989; his mother still lives in Iran.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011