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