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her business expenses, she produced copies of canceled checks
that included payments for personal expenses, such as a check
payable to Victoria's Secret, and payments relating to
maintenance of the home she shared with her mother.
This case is the seventh case commenced in this Court by
petitioner in which she claimed deductions relating to her
tutoring and counseling activity. The prior cases for the years
indicated were resolved as follows:
Year Disposition
1979 Issue decided in favor of
petitioner in a summary opinion
filed Oct. 25, 1983
1984 Stipulated decision entered
(no deficiency) Apr. 25, 1988
1986 & 1987 Deductions denied and additions
to tax sustained, T.C. Memo.
1991-162, filed Apr. 9, 1991
1988 Deductions denied, T.C. Memo.
1993-310, filed July 15, 1993
1989 Deductions denied and additions
to tax sustained, T.C. Memo.
1996-175, filed Apr. 10, 1996
1991 Deductions denied and penalties
imposed, including award under
sec. 6673, in bench opinion
rendered June 28, 1995
Petitioner's return for 1990 was filed May 21, 1993. Attached to
her return was a letter dated May 10, 1993, which stated, among
other things:
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