- 3 -
petitioner is entitled to itemized charitable contribution
deductions in the amounts of $6,472 in 1993 and $6,813 in 1994;
and (4) whether petitioner is liable for accuracy-related
penalties pursuant to section 6662.3
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. At the time the petitions were filed, petitioner
resided in Norfolk, Virginia.
Prior to the years in issue, petitioner graduated from
college and received a bachelor's degree in business
administration and accounting. Petitioner worked over 19 years
as a national bank examiner and has more than 24 years of
professional experience in banking, accounting, and auditing.
During the years in issue, petitioner was engaged in two
different activities which she reported on Schedules C, Profit or
Loss From Business, of her 1993 and 1994 Federal income tax
returns. On Schedules C, attached to her 1993 and 1994 income
tax returns, petitioner listed her principal business or
profession as "wholesale merchant" and "wholesale sales"
3Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011