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Federal income tax in the amount of $4,256 and an addition to tax
of $400 pursuant to section 6651(a)(1).
The issues for decision are: (1) Whether petitioner was
engaged in a trade or business during 1993; if so (2) whether
petitioner substantiated certain expenses relating to the trade
or business; and (3) whether petitioner is liable for the
delinquency addition to tax.
FINDINGS OF FACT
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 El Toro, California.
During 1993, petitioner worked for the Immigration and
Naturalization Service (INS) in the asylum office as one who
interviewed refugees who come to the United States. Petitioner
also worked as a part-time professor at Chapman University
(Chapman) teaching classes in philosophy and religion and as a
chaplain for the United States Navy (the Navy), lecturing and
performing religious services. Petitioner is an ordained
minister of the United Church of Christ and has been for the past
40 years.
Before 1993 and over the course of his career, petitioner
worked in many different capacities, including working as a
professor at different colleges and universities, working on
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