Some of the issues raised by the pleadings have been
disposed of by agreement of the parties, leaving for decision:
(1) Whether this Court has jurisdiction over this case based on
the notice of deficiency mailed to petitioner with one digit of
the street address missing; (2) whether petitioner is entitled to
relief under section 6013(e) as an innocent spouse and, if so, to
what extent; (3) whether petitioner is entitled to deductions in
excess of the amounts allowed by respondent for expenses incurred
by her late husband in connection with his business; and (4)
whether petitioner is liable for the accuracy-related penalty as
determined by respondent pursuant to section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
Petitioner was a legal resident of Los Angeles, California,
at the time of the filing of the petition in this case.
Petitioner filed a joint Federal income tax return with her late
husband, Mr. Richard Velinsky (Mr. Velinsky), for the taxable
year 1990.
On a Schedule C attached to petitioner's 1990 joint return
are reported income and expenses of Mr. Velinsky's entertainment
and band management business (the Schedule C). Mr. Velinsky
operated this business as the sole proprietor. Mr. Velinsky died
1(...continued)
the Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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