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Respondent determined a deficiency of $9,931 and an addition
to tax, under section 6651(a)(1), of $262 in petitioners' Federal
income tax for 1993.
Following concessions by the parties, the issues remaining
for decision are: (1) Whether petitioners are entitled to an
automobile rental expense deduction for 1993 as a trade or
business expense under section 162(a), and (2) whether
petitioners are liable for the addition to tax, under section
6651(a)(1), for failure to timely file a Federal income tax
return.
Some of the facts were stipulated, and those facts, with the
annexed exhibits are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners'
legal residence was Salt Lake City, Utah.
Derk O. Pehrson (petitioner husband) is a licensed real
estate broker in the State of Utah and was engaged in the
business of real estate sales during the year at issue.
Petitioner husband was also employed by Colonial Mortgage during
1993. His wife, Julia K. Pehrson (petitioner wife), was employed
as a vice president of Hercules Credit Union (Hercules) during
the year at issue.
In August 1993, petitioners rented a vehicle and drove,
along with their two young children, from Salt Lake City to
Orlando, Florida. On their way to Orlando, the family drove
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