- 2 -
Respondent determined a deficiency in petitioners' 1994
Federal income tax in the amount of $3,595 and an accuracy-
related penalty under section 6662(a) in the amount of $719.
After concessions by the parties, the issues for decision
are: (1) Whether petitioners are entitled to Schedule C
deductions in excess of the amounts allowed by respondent, and
(2) whether petitioners are liable for an accuracy-related
penalty under section 6662(a).
Some of the facts have been stipulated and are so found.
Petitioners resided in Brooklyn, New York, at the time their
petition was filed.
During 1994, petitioner Marian Januszewski (petitioner)
worked as a limousine driver for the Excel Limousine Corporation
(Excel). Excel primarily served corporate clients in the
Manhattan area in New York City. Petitioner worked for Excel as
an independent contractor. Petitioner owned his own limousine, a
Mercury Grand Marquis.
On Schedule C, Profit or Loss From Business, of their 1994
Federal income tax return, petitioners claimed expenses in the
amount of $41,155 from petitioner's activity as a limousine
driver. On their 1994 return, petitioners reported, among other
things, taxable interest income in the amount of $98.
On October 16, 1996, petitioners filed a Form 1040X, Amended
U.S. Individual Income Tax Return (amended return). Petitioners
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011