- 2 - Year1 Deficiency Sec. 6662(a) 1993 $3,043 $609 1994 2,227 445 1995 84 -0- 1 Docket No. 18435-96 pertains to 1994, and docket No. 27179-96 pertains to 1993 and 1995. After concessions by petitioner,2 the issues for decision are: (1) Whether petitioner is entitled to deduct business expenses on Schedule C for 1993 and 1994 or whether the deductions belong to his corporation; (2) if we hold that he is entitled to deduct the business expenses, whether petitioner has substantiated the expenses; and (3) whether petitioner is liable for the accuracy-related penalties under section 6662(a) for negligence or disregard of rules or regulations. Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time he filed his petition, petitioner resided in Chatsworth, California. Background 2 In the notice of deficiency for 1993, respondent determined that petitioner had an unreported capital gain of $1,128. In the notice of deficiency for 1995, respondent disallowed a claimed capital loss on the ground that petitioner did not prove that the stock was worthless in that year. Petitioner conceded both issues at trial.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011