- 2 - The issues for decision are: (1) Whether petitioner is entitled, under section 162(a), to cost of goods sold and deductions for trade or business expenses incurred in connection with a book-selling activity, and (2) whether petitioner is liable for the addition to tax under section 6651(a)(1). Some of the facts were stipulated. Those facts, with the exhibits offered in connection therewith, are so found and are incorporated herein by reference. Petitioner was a resident of Silver Spring, Maryland, at the time the petition was filed. During 1988, petitioner sold books, an activity he began sometime during 1987 following a career as a life insurance agent. Petitioner sold his books at conventions and seminars in various parts of the United States. Most of the places where petitioner sold his books were religious gatherings or conventions, and most of his books were of a religious nature; however, sometime during 1988, he began selling secular books together with the religious books. Petitioner generally rented one or more booths or exhibit spaces at each convention, where he displayed and sold his books. Petitioner did not have a fixed retail place of business. When he was not attending a convention, he stored his book inventory at home. He did not conduct any sales activity at home. Petitioner did not employ anyone, but, frequently, his wife and daughter accompanied him and assisted in his sales.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011