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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