Diana Lynn Taub - Page 2

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          6651(a)(1), and a $1,108 penalty under section 6662.1  For 1990,            
          respondent determined that petitioner was liable for a $8,392               
          deficiency, a $1,673 addition under section 6651(a)(1), and a               
          $1,678 penalty under section 6662.                                          
               The Court tried this case on December 4, 1995.  The evidence           
          consists primarily of a stipulation of four facts, a stipulation            
          of three exhibits, and the scant testimony of petitioner.                   
          One stipulation concerns petitioner’s residence at the time of              
          the petition, which was Pembroke Pines, Florida.  The other three           
          stipulations reference the stipulated exhibits; namely, the                 
          subject notice of deficiency and petitioner's 1989 and 1990 Forms           
          1040, U.S. Individual Income Tax Return.  Petitioner's testimony,           
          including direct examination and cross-examination, is 10 pages             
          in the transcript.                                                          
               We must decide the issues set forth below.  For purposes of            
          clarity and convenience, each issue states our findings of fact             
          and Opinion with respect thereto.                                           
               1.  Issue One                                                          
               We decide whether petitioner is entitled to certain amounts            
          for costs of goods sold and expenses, that respondent disallowed.           
          Petitioner reported these amounts on her 1989 and 1990 Schedules            
          C, Profit or Loss From Business (Sole-Proprietorship).                      

               1 Unless otherwise stated, section references are to the               
          Internal Revenue Code in effect for the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded to the nearest dollar.                           




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