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MEMORANDUM OPINION
NIMS, Judge: Respondent determined a deficiency in
petitioner's Federal income tax for 1993 in the amount of
$11,129, and an accuracy-related penalty under section 6662(a)
for 1993 in the amount of $2,226. All section references are to
sections of the Internal Revenue Code in effect for 1993, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
There are two issues for decision. The first is whether
petitioner is entitled to reduce Schedule C gross receipts or
sales by claimed returns and allowances in the amount of $45,243.
(Respondent's disallowance of this amount resulted in a self-
employment tax liability and a corresponding deduction of one-
half the amount thereof, both of which are reflected in the
$11,129 income tax deficiency determined by respondent, but which
must be recomputed in accordance with discussion infra.) The
second issue for decision is whether petitioner is liable for the
accuracy-related penalty under section 6662(a).
Some of the facts were stipulated and are so found.
Petitioner resided in Corona Del Mar, California, at the time he
filed his petition.
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Last modified: May 25, 2011