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Respondent determined a deficiency in petitioner's Federal
income tax for 1993 in the amount of $5,398.
The issues for decision are: (1) Whether petitioner is
entitled to exclude from gross income certain per diem payments
which he received during 1993; (2) whether petitioner's horse
selling and leasing activity was an activity not engaged in for
profit within the meaning of section 183; (3) whether certain
expenses paid by petitioner in connection with his aviation
activity are deductible as ordinary and necessary business
expenses; and (4) whether petitioner is entitled to Schedule A
itemized deductions which exceed his claimed standard deduction.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner claimed he resided in
Antioch, Tennessee, on the date the petition was filed in this
case.
Petitioner has been a certified public accountant since
1972. He founded an accounting firm in Minneapolis, Minnesota,
in 1974 which, sometime prior to 1993, was incorporated under the
laws of Minnesota as a professional corporation called Romer &
Company, P.C. (Romer). During 1993, petitioner was an 8-percent
shareholder and the president of Romer. Derf Bistodeau, Romer's
vice president, owned the remaining 92 percent of Romer's shares.
1(...continued)
Practice and Procedure.
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