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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