Ghalardi Income Tax Education Foundation - Page 12

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                  Second, respondent disallowed the cost of goods sold                
             claimed on the Schedules C for Mr. Webber's tax consulting               
             business in the amount of $168 in 1992 and $7,383 in 1993.               
             Third, respondent disallowed the expenses claimed on the                 
             Schedules C, $24,989 in 1992 and $14,208 in 1993, on the                 
             ground that Mr. Webber had not substantiated any of these                
             expenses.  Fourth, respondent increased Mr. Webber's                     
             taxable income by Ghalardi's gross receipts for 1993,                    
             $38,430.  The notice of deficiency sets forth the follow-                
             ing explanation of this adjustment:                                      

                  It has been determined that Ghalardi ITEF                           
                  operates as an agent of William S. Webber.                          
                  Income from Ghalardi ITEF is being reassigned to                    
                  William S. Webber in the amount indicated below                     
                  [i.e., $38,430].                                                    

             Fifth, respondent decreased Mr. Webber's taxable income by               
             one-half of the additional self-employment tax determined                
             for the year, $3,821 for 1992 and $4,269 for 1993.                       
                  Sixth, respondent determined that Mr. Webber is                     
             liable for the addition to tax under section 6651(a)(1)                  
             for failure to file Mr. Webber's 1993 return on or before                
             Monday, October 17, 1994, the due date including                         
             extensions.  Finally, respondent determined that Mr. Webber              
             is liable for the accuracy-related penalty under section                 
             6662(a) for 1992 and 1993 on the ground that the under-                  





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