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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011