- 2 -- 2 - under section 6651(a)(1) in the amount of $162, and an accuracy- related penalty under section 6662(a) in the amount of $256. Petitioner resided in Hollywood, Florida, at the time he filed his petition. After concessions, the remaining issues are: (1) Whether petitioner is liable for the addition to tax under section 6651(a)(1); and (2) whether petitioner is liable for the accuracy-related penalty under section 6662(a). The facts may be summarized as follows. Petitioner is an insurance agent. Petitioner filed two Schedules C with his 1994 return, only one of which was questioned by respondent in the notice of deficiency. On the Schedule C in issue, petitioner classified himself as a statutory employee and reported a net loss of $8,543. In the notice of deficiency, respondent disallowed the loss claimed on the Schedule C for lack of substantiation. The disallowed expenses related to deductions claimed for office expenses, "dues and subscriptions", and automobile expenses.2 Petitioner's 1994 return was originally due on April 17, 1995.3 Sec. 6072(a). Petitioner applied for and received an 2 The parties stipulated that petitioner is entitled to $6,007 of the $8,543 in expenses claimed on the Schedule C, thereby resolving the substantiation issue raised in the notice of deficiency. 3 Because April 15, 1995, fell on a Saturday, a return filed on the following Monday is deemed timely under sec. 7503.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011