-2- determination that petitioners underreported their income and overstated Schedule C deductions for 1992. The specific issues we must resolve are: (1) Did petitioners underreport their income in 1992 by $25,112? Respondent determined this amount through the bank deposits method, showing total deposits of $82,072,1 of which $45,332 was reported by petitioners on their tax return and $11,628 was conceded by respondent at trial as nontaxable. We find that the $25,112 difference came from nontaxable sources; thus, we hold that petitioners did not underreport their 1992 income by $25,112. (2) Must petitioners include $7,220 in income, representing the market value of a trip to Scotland and England petitioner Gregory A. Maslow earned in 1992 as a sales award from Kentucky Central Life Insurance Co.? We hold they must. (3) Are petitioners entitled to deduct various claimed Schedule C business expenses that respondent disallowed? We hold that petitioners are entitled to a portion, but not all, of the claimed Schedule C business expenses, as explained in greater detail infra. (4) Are petitioners liable for the accuracy-related penalty under section 6662 for 1992 and for an addition to tax for failure 1 The notice of deficiency states in one instance that the deposits for 1992 total $80,096 and in another instance $81,029. On brief, respondent states the total deposits as $82,072. On the basis of our holding that the unidentified deposits are not taxable, the differing deposit amounts are of no importance.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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