Janet Phillips - Page 2

                                        - 2 -                                         

          1993      17,755              4,439               3,551                     
               All section references are to the Internal Revenue Code in             
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.  After concessions by            
          petitioner, the issues for decision are as follows:                         
               1.  Whether petitioner is entitled to a deduction for                  
          business expenses.  We hold that she is not.                                
               2.  Whether petitioner is liable for additions to tax for              
          failing to file her tax returns in a timely manner.  We hold that           
          she is.                                                                     
               3.  Whether petitioner is liable for accuracy-related                  
          penalties for negligence.  We hold that she is.                             
                                     Background                                       
               The facts have been fully stipulated under Rule 122 and are            
          so found.  Petitioner resided in Bensalem, Pennsylvania, at the             
          time she filed her petition.                                                
               Petitioner's husband, Glenn W. Phillips, was the sole                  
          shareholder of N.H.R. Corp. (NHR).  Petitioner, who had no                  
          affiliation with NHR, owned a disability insurance policy which             
          in 1992 and 1993 paid her $60,000 and $90,000, respectively,                
          allegedly to cover the cost of NHR's overhead expenses.                     
               On October 14, 1994, petitioner filed Federal income tax               
          returns for 1992 and 1993.  On the returns, petitioner selected             
          married filing separate status and did not report the benefits              





Page:  Previous  1  2  3  4  5  Next

Last modified: May 25, 2011