- 12 -
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-
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011