Michael and Christa Dee Richardson - Page 2

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               Respondent determined a deficiency in petitioners' 1993                
          Federal income tax in the amount of $2,380, an addition to tax              
          under section 6651(a) in the amount of $187.15, and an accuracy-            
          related penalty under section 6662 in the amount of $476.                   
               The issues are:  (1) Whether petitioners are entitled to               
          claim a theft loss; (2) whether petitioners are liable for the              
          addition to tax under section 6651(a)(1); and (3) whether                   
          petitioners are liable for the accuracy-related penalty under               
          section 6662(a).                                                            
               Some of the facts have been stipulated and are so found.               
          Petitioners resided in Ogden, Utah, at the time the petition was            
          filed.                                                                      
               Petitioner Michael Richardson (petitioner) filed a Schedule            
          C with his 1993 Federal income tax return.  On the Schedule C, he           
          listed his business as mining with a business name of Shoe String           
          Mining.  No income or expenses were listed except for $8,500 of             
          "other" expenses which resulted in a loss in that amount.  On the           
          Schedule C, petitioner stated that the $8,500 was "stolen                   
          equipment not covered by insurance" and listed:                             
               955 Catapiller [sic] Track Loader   5000                               
               35 KW Diesel Gen.                 3000                                 
               Water Pump                           500                               
               In the notice of deficiency, respondent disallowed the                 
          $8,500 claimed loss.                                                        







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