- 2 - 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 drovePage: Previous 1 2 3 4 5 6 7 8 9 Next
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