- 2 - 1993 16,342 -- Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions by petitioners, the issues for decision are as follows: 1. Whether petitioners, pursuant to section 162(a), are entitled to deduct certain expenses as ordinary and necessary business expenses. We hold that petitioners are not so entitled. 2. Whether petitioners, pursuant to section 6662(a), are liable for an accuracy-related penalty. We hold that petitioners are liable. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioners resided in Antioch, California. During the years in issue, petitioners operated a day-care service in their home. In addition to their own children, petitioners cared for one child in 1992 and four children in 1993. During 1993, petitioners also operated from their home Simpson & Associates, a business that marketed Amway Corp. products, and Equity Investments, a business that sold mortgage reduction plans. During the years in issue, Scott Simpson wasPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011