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February of 1991; (7) whether petitioners are entitled to
Schedule C business expense deductions for legal and professional
expenses of $10,000 claimed for 1990 and $13,000 for 1991; (8)
whether petitioners failed to report interest income of $2,824
for 1990; (9) whether petitioners are entitled to Schedule C
business expense deductions for self-employment tax of $7,849 for
1990 and $10,246 for 1991; (10) whether the assessment of a
deficiency for the taxable year 1990 is barred by the 3-year
period of limitations provided in section 6501(a); (11) whether
petitioners are liable for the additions to tax pursuant to
section 6651(a)(1) for failure to file timely Federal income tax
returns for 1990 and 1991; and (12) whether petitioners are
liable for accuracy-related penalties pursuant to section 6662(a)
for 1990 and 1991.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein by this reference.
At the time the petition was filed in this case, Jane B.
Oliver and Robert P. Oliver resided in Greenville, Mississippi.
Petitioners, who are cash basis taxpayers, filed their joint
Federal income tax returns for the taxable years 1990 and 1991 on
August 19, 1991, and July 20, 1992, respectively.
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