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Accuracy-related Penalty
Year Deficiency Sec. 6662
1993 $7,686 $149
1994 8,776 1,626
After concessions,2 the issues remaining for decision are:
(1) Whether petitioner is entitled to reduce gross receipts in
her wholesale activity by certain amounts for cost of goods sold;
(2) whether petitioner is entitled to deduct various expenses
incurred in her wholesale and consulting activities; (3) whether
2Petitioner concedes that for the taxable year 1993, she
omitted from income interest income from Marbury Associates of
$43 and interest income of $44 from Riggs National Bank; wages in
the amount of $817 received from Leger Enterprises, Ltd.; and
nonemployee compensation income in the amount of $1,215 received
from Hanover Capital Partners, Ltd. Petitioner also concedes
that she is not entitled to a deduction for professional services
expenses in 1993 related to her wholesale activity; travel and
entertainment expenses in 1993 and 1994 to the extent that such
deductions are comprised of expenses other than telephone,
laundry, gas, and tolls; and a charitable contribution expense of
$1,000 in 1994 reported on Schedule C in relation to her
wholesale activity.
For the taxable year 1993, respondent concedes that
petitioner is entitled to deduct car and truck expenses in the
amount of $311; tolls in the amount of $5 related to petitioner's
wholesale activity; telephone expenses in the amount of $323
related to her consulting activity; and additional charitable
contributions in the total amount of $4,803, in addition to the
$922 allowed in the notice of deficiency. Respondent also
concedes that petitioner is entitled to claim an additional
credit in the amount of $109 for withholding tax on income
petitioner received from Leger Enterprises, Ltd. in 1993.
For the taxable year 1994, respondent concedes that
petitioner is entitled to deduct legal and professional fees
related to petitioner's consulting activity in the amount of $205
and charitable contributions in the total amount of $5,855.
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