- 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