- 2 -
The parties have agreed to certain adjustments for the
taxable years 1992 and 1993. The following issues remain for
decision:
(1) Whether petitioners are entitled to deduct rental
expenses for 1992 in excess of those conceded by respondent.
(2) Whether petitioners are entitled to deduct mileage
expenses for 1992 and 1993 in excess of those conceded by
respondent.
(3) Whether petitioners' cost of goods sold for 1993 for
their business of Hi Fidelity Record was correctly reported on
Schedule C of their amended Federal income tax return.
(4) Whether the markup percentage used by respondent for
the goods sold was correct in determining petitioners' gross
receipts for 1992 and 1993.
(5) Whether petitioners are liable for the accuracy-related
penalties under section 6662(a)1 for 1992 and 1993.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein. Petitioners resided in Rialto, California,
when their petition was filed.
1 All section references are to the Internal Revenue Code
in effect for the years at issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011