- 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.
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