Julie Pusateri - Page 2

          the year in issue.  All Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
               Respondent determined a deficiency in petitioner's 1991                
          Federal income tax in the amount of $7,795, together with an                
          accuracy-related penalty under section 6662(a) of $1,356.                   
               We must decide:  (1)  Whether petitioner improperly reported           
          income and deductions on two Schedules C and on a Schedule E                
          attached to her 1991 Federal income tax return; (2) whether                 
          petitioner is subject to additional self-employment tax;                    
          (3) whether petitioner is entitled to a child care credit; and              
          (4) whether petitioner is liable for an accuracy-related penalty            
          under section 6662(a).                                                      
               Some of the facts have been stipulated and they are so                 
          found.  Petitioner resided in Solana Beach, California, when her            
          petition was filed.                                                         
               For clarity and convenience, our findings of fact and                  
          opinion have been combined.                                                 
               During 1991, petitioner was married but separated from her             
          husband.  During that year, petitioner was a paralegal licensed             
          to practice in California.  She operated two paralegal                      
          businesses.  On her 1991 Federal income tax return, petitioner              
          reported income and expenses of her two paralegal business on two           
          Schedules C, "Julie Pusateri-Paralegal" (Schedule C-1), and                 
          "Legal Assistance Center" (Schedule C-2).  The parties have used            
          the Schedule C-1 and Schedule C-2 terminology and so shall we.              

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