- 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 benefitsPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011