2
Respondent determined deficiencies in, additions to, and a
penalty on petitioner's Federal income taxes as follows:
Additions to Tax Penalty
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6654(a) 6662(a)
1988 $3,088 $408 $160 --- N/A
1989 5,760 1,393 N/A --- $1,152
1990 7,721 1,930 N/A $10 ---
1991 6,880 1,720 N/A 397 ---
After concessions,2 the issues for decision are: (1)
Whether petitioner is entitled to amortization deductions with
respect to certain intangible assets acquired in connection with
her business of being a Safeguard distributor; and (2) whether
petitioner is allowed to carry forward net operating losses
sustained in taxable years 1988, 1989, and 1990.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by this reference. Petitioner resided in
Dallas, Texas, at the time her petition was filed.
Petitioner began working in the printing business in 1968 in
the Dallas-Fort Worth area of Texas. She was employed in the
early 1970's as a salesperson and sales manager for a company
2 Petitioner concedes she is liable for the additions to tax
under sec. 6651(a)(1) for each taxable year in issue, and under
sec. 6654(a) for the taxable years 1990 and 1991. Respondent
concedes the addition to tax under sec. 6653(a)(1) for 1988 and
the penalty under sec. 6662(a) for 1989. Petitioner concedes she
is liable for self-employment tax on her taxable income as
finally redetermined, and agrees to all of the arithmetical
adjustments set forth in the notice of deficiency to the amount
of taxable income as finally redetermined.
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