- 2 - Respondent determined a deficiency in petitioners' Federal income tax for 1994 in the amount of $9,200. After a concession by respondent,2 the issue remaining for decision is whether petitioners are entitled to business expense deductions. Some of the facts have been stipulated and are so found. The stipulations of fact and attached exhibits are incorporated herein by this reference. Petitioners resided in Phoenix, Arizona, on the date the petition was filed in this case. All references to petitioner in the singular are to Kenneth Smith. All of respondent's substantive adjustments in the statutory notice of deficiency involve amounts claimed with respect to petitioner's involvement with Tracstar Simulcasting, Inc. (Tracstar).3 Tracstar provided live satellite transmission of dog and horse races to various off-track betting (OTB) locations. It installed all of the equipment at the racetracks and the OTB locations necessary for sending and receiving the satellite signals. The racetracks were generally located in Arizona, but 2 In the event that the Court holds that petitioners are not entitled to the claimed Schedule C deduction for interest paid with respect to their motor homes, respondent concedes that petitioners are entitled to an additional sec. 163(h)(3) qualified residence interest deduction for such interest. 3 Respondent's adjustment to petitioners' liability for alternative minimum tax is computational and will be resolved by the Court's holding on the issue in this case.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011