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Penalty
Year Deficiency Sec. 6662(a)
1992 $8,376 $1,675
1993 8,137 1,627
All section references are to the Internal Revenue Code in
effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
At the time the petition herein was filed, petitioner was a
resident of Birmingham, Alabama. He filed his income tax returns
for the years 1992 and 1993 on the basis of married filing
separately. In the years in issue, petitioner was employed as a
policeman for the Fairfield Police Department. He also provided
private security service and was a member of the Coast Guard
Reserve during these years.
At trial herein, petitioner appeared on behalf of himself.
Although he testified, he produced no other witnesses, and no
documentary evidence of any sort was offered in support of his
position. He admitted at trial that he failed to substantiate
any of the business expenses claimed on Schedule C of his 1992
and 1993 tax returns, and he also admitted that he did not
substantiate any of the claimed deductions on Schedule A of his
1992 and 1993 tax returns.
The adjustments made by respondent to petitioner's taxable
returns were as follows:
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Last modified: May 25, 2011