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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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