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Court Rules of Practice and Procedure, unless otherwise
indicated.
After a concession,1 the issues for decision are as follows:
(1) Whether petitioners are entitled to previously unclaimed
Schedule C deductions in excess of the amount conceded by
respondent. We find they are not.
(2) Whether petitioners are liable for an addition to tax
pursuant to section 6651 for late filing. We hold they are.
(3) Whether petitioners are liable for a penalty pursuant to
section 6662 for negligence. We hold they are.
Certain automatic adjustments will be required in the
calculation of self-employment tax and related items of a
computational nature flowing from our findings.
Some of the facts have been stipulated and are so found.
The stipulated facts and accompanying exhibits are incorporated
into our findings by this reference. When they filed their
petition herein, petitioners resided in Oakland, California.
Petitioners filed their individual Federal income tax return
for 1993 on October 13, 1995. The return was due on April 15,
1994. Petitioners had neither sought nor been granted an
extension of time in which to file.
1 Petitioners conceded that Mr. Kern Smith (petitioner)
received $183,585 as self-employment income which petitioners
failed to report. Respondent conceded petitioners are entitled
to deduct $114,394 in previously unclaimed deductions.
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