- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011