- 2 -
Respondent determined a deficiency in petitioner's Federal
income tax for 1992 in the amount of $5,127, an addition to tax
pursuant to section 6651(a)(1) in the amount of $1,313, and an
accuracy-related penalty pursuant to section 6662(a) in the
amount of $1,025.
The issues for decision are: (1) Whether petitioner is
entitled to Schedule C business expense deductions; (2) whether
petitioner is liable for the section 6651(a)(1) addition to tax;
and (3) whether petitioner is liable for the section 6662(a)
accuracy-related penalty.2
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Hollywood, Florida, on the date the petition was filed in this
case.
Petitioner works as a self-employed musician and band
manager. She and her husband, Matthew Genck, are members and
managers of a jazz band named "Paris" (the band). Petitioner
spends an average of 12 hours per week performing as the band's
lead singer. Matthew plays the bass guitar. Although petitioner
and Matthew are primarily responsible for managing the band, they
generally split the band's profits and expenses three ways with
2 Respondent's adjustments to petitioner's liability for
self-employment taxes and deduction for one-half of such
liability are computational and will be resolved by the Court's
holdings on the issues in this case.
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