Scott C. and Patricia A. Simpson - Page 2

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                    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 was              






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