Polly M. Cherry - Page 7

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          accorded her a corresponding income tax deduction in the amount             
          of $888.                                                                    
               Respondent further determined that petitioner was liable for           
          additions to tax and penalties arising from her 1993 and 1994               
          returns.  For 1993, respondent determined that petitioner owed              
          $1,373 pursuant to section 6651(a)(1) for failure to file a                 
          timely return, and $1,958 pursuant to section 6662(a) as an                 
          accuracy-related penalty.  For 1994, respondent determined that             
          petitioner owed $1,375 pursuant to section 6662(a) as an                    
          accuracy-related penalty.1                                                  
                                       OPINION                                        
          Disallowed Deductions                                                       
               Mileage                                                                
               The largest deductions claimed by petitioner on her Schedule           
          C's for the years in issue were $13,160 for mileage driven in               
          1993 and $13,050 for mileage driven in 1994.  Respondent                    
          determined that petitioner failed to substantiate her mileage               
          deductions as required by section 274(d) and, therefore, limited            
          the deduction to $4,000 for mileage for each of the years in                
          issue.  Subject to respondent's concessions, we sustain                     
          respondent's determination for 1993 in toto.  For 1994, we                  
          sustain respondent's determination only in part.                            

          1    In addition, respondent determined that petitioner owed,               
          pursuant to sec. 6654, $275 in 1993 and $175 in 1994 for failure            
          to pay estimated taxes.  Because petitioner filed income tax                
          returns for both years this Court has no jurisdiction and does              
          not consider these additions to tax.  See sec. 6665(b)(2).                  



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