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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
The issues for decision are: (1) Whether petitioner is
entitled to claimed deductions for business expenses for the year
1986. We hold he is to the extent set out below. (2) Whether
petitioner is liable for an addition to tax under section 6651
for the year 1986. We hold he is. (3) Whether petitioner is
liable for an addition to tax under section 6654 for the year
1986. We hold he is.
Some of the facts have been stipulated and are so found.
The stipulated facts and accompanying exhibits are incorporated
herein by this reference. Petitioner resided in Sunrise,
Florida, at the time the petition was filed.
In 1986, petitioner was employed by U.S. Geological
Services, Inc. This was an S corporation of which petitioner was
the sole stockholder and its only employee. The corporation was
located in Las Vegas, Nevada, and its business purpose was to
negotiate oil and gas leases.
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