- 2 - The only issue for decision is whether petitioner is entitled to deduct certain business expenses, which she claimed on Schedule C of her 1994 return, in excess of the amounts allowed by respondent.2 Background 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 of filing the petition, petitioner resided at Palo Alto, California. For clarity and convenience, we have combined the findings of fact and discussion of pertinent legal issues. In March 1990, petitioner entered into an agreement with a company named Au Pair In America (hereinafter APIA). The agreement was titled "Community Counselor Letter of Agreement" and provided in part that The Community Counselor interviews potential Host Families to evaluate their appropriateness for the [APIA] Program, matches Host Families with Au Pairs, has responsibility for a cluster of area Au Pairs throughout the year's exchange and generally facilitates the Host Family/Au Pair relationship. 2 Respondent's notice of deficiency also reduced petitioner's total itemized deductions from $13,219 to $11,056 and increased petitioner's self-employment tax from $376 to $1,219. The parties appear to agree that these adjustments are dependent upon the other adjustments, and therefore, we do not separately address them. To the extent that petitioner seeks an abatement of interest (or review thereof), she must make such a request to the Commissioner and await a final determination not to abate interest. Sec. 6404(g); see Bourekis v. Commissioner, 110 T.C. 20, 27 (1998).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011