- 2 - 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, the issues remaining for decision are: (1) Whether petitioners overstated gross income on their 1989 Schedule C; (2) whether petitioners are entitled to a theft loss deduction in 1989; (3) whether petitioners are entitled to deductions for charitable contributions in 1989, 1990, and 1991; (4) whether for 1991 petitioners are entitled to additional deductions on Schedule C or to an additional deduction for mortgage interest; and (5) whether petitioners are liable for the section 6651(a)(1) addition to tax for 1990 and 1991. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. At the time of the filing of their petition, petitioners resided in Hyattsville, Maryland. During the years in issue, Robert Tolbert (petitioner) operated a construction business known as Tolbert's Construction. Petitioner reported the income and expenses from this business on Schedule C. Petitioner did not maintain any books or records for Tolbert's Construction during 1989, 1990, or 1991. Tolbert's Construction had several different jobs during 1989, including the following:Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011