Maurzal Frias and Teresa Frias - Page 2

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          All section references are to the Internal Revenue Code in effect           
          for the years in issue, and all Rules references are to the Tax             
          Court Rules of Practice and Procedure.                                      
               After concessions,1 the issues for decision are:                       
               (1) Whether petitioners underreported their Schedule C gross           
          receipts for the years 1991 and 1992 in the amounts of $9,733 and           
          $16,403, respectively;                                                      
               (2) whether petitioners are entitled to Schedule C                     
          deductions for car and truck expenses for the years 1991 and 1992           
          in amounts greater than those allowed by respondent; and                    
               (3) whether petitioners are liable for accuracy-related                
          penalties under section 6662(a) for negligence or disregard of              
          rules or regulations.                                                       
                                  FINDINGS OF FACT                                    
               Petitioners, husband and wife, lived in Tulsa, Oklahoma, at            
          the time the petition was filed in this case.                               
               During 1991 and 1992,2 Mr. Frias was self-employed primarily           
          as a house painter.  He also worked as a musician and magician.             
          Petitioners reported their gross income and deductions on one               
          Schedule C; they described their principal business as                      
          "Painting/Music".  Petitioners were cash basis taxpayers.                   
          Petitioners' tax returns were prepared by Richard Gardner.                  


               1  On brief, petitioners have conceded the sec. 6651(a)                
          issue.                                                                      
               2  Unless otherwise indicated, all descriptions refer to the           
          1991 and 1992 tax years.                                                    



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