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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.
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