Michael S. Palmer - Page 2

                                          2                                           
               The issues for decision are:                                           
               1.   Whether petitioner may deduct business expenses in the            
          amount of $70,170.68 for 1992 and $58,369.81 for 1993, as                   
          petitioner contends; $17,924 for 1992 and $16,004 for 1993, as              
          respondent contends; or some other amounts.  We hold that                   
          petitioner may deduct business expenses of $17,924 for 1992 and             
          $16,004 for 1993.                                                           
               2.   Whether petitioner is liable for the self-employment              
          tax imposed by section 1401 for 1992 and 1993.  We hold that he             
          is.                                                                         
               3.   Whether petitioner is liable for the addition to tax              
          for failure to file under section 6651(a)(1) for 1992 and 1993.             
          We hold that he is.                                                         
               4.   Whether petitioner is liable for the addition to tax              
          for underpaying his estimated taxes under section 6654 for 1992             
          and 1993.  We hold that he is.                                              
               Unless otherwise indicated, section references are to the              
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
                                  FINDINGS OF FACT                                    
          A.   Petitioner                                                             
               Petitioner lived in Marietta, Georgia, when he filed the               
          petition in this case.  He was married during the years in issue.           








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