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from Marion Tile, Inc. and Brisson Flooring, Inc. reflected
Federal income tax withholdings in the amounts of $58 and $826.89
respectively.
Petitioner never filed a Federal income tax return for 1989.
He contends that if Carolina Acoustical had issued him a Form W-2
instead of Form 1099, he would have filed a timely return and
paid his tax liability. He expressed concern over not receiving
a Form W-2 to Government officials at the Internal Revenue
Service (IRS), and they advised him to file a return using his
Form 1099. Despite this advice, petitioner waited for his Form
W-2, believing the Form 1099 was a mere "formality".
Upon examination, respondent determined a deficiency in
petitioner's Federal income tax of $1,849. In calculating
taxable income, respondent allowed petitioner to deduct payments
for workmen's compensation insurance, gasoline expenses, and van
rental charges as ordinary and necessary business expenses
pursuant to section 162(a).
Respondent determined, however, that miscellaneous itemized
deductions should be limited by the 2-percent floor as prescribed
by section 67(a) and that petitioner is not entitled to deduct
loan and cash advance repayments. Respondent also imposed a
section 6651 delinquency addition to tax and a section 6654
addition to tax for failure to pay estimated tax, finding that
none of the exceptions apply.
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