Subhendu Das - Page 2

                                        - 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