- -5
Respondent's notice of deficiency disallowed $30,773 of the
$58,430 of claimed cost of goods sold. Most of the $27,657
allowed by respondent as cost of goods sold was amounts Mr.
Velinsky expended in connection with the production of a music
video (the video) made for a band called "The Replacements".
Respondent now concedes that, in addition to the cost of goods
sold items allowed in the notice of deficiency, petitioner is
entitled to an additional $149.45 for photography expenses.
Respondent also concedes that petitioner has satisfied all
elements of section 6013(e), except the provision of section
6013(e)(1)(B) that the understatement of tax is attributable to
grossly erroneous items. Respondent's notice of deficiency to
petitioner was addressed to petitioner at 340 Centinela #A, Los
Angeles, California 90066. Petitioner filed a timely petition on
April 1, 1994, alleging error in respondent's determination as
set forth in this notice of deficiency.
OPINION
Petitioner contends that since the notice of deficiency
dated January 7, 1994, was mailed to 340 Centinela #A, rather
than to 3402 Centinela Avenue, the jurisdictional requirements of
section 6212 have not been met. The address on petitioner's 1990
Federal income tax return is 1385 Vienna Way, Venice, California.
However, based on an exhibit in evidence with respect to the year
1990, petitioner stated that the proper address for the notice of
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