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MEMORANDUM OPINION
NIMS, Judge: Respondent determined the following deficiency
and accuracy-related penalty with respect to petitioner's Federal
income taxes as follows:
Income Tax Penalty
Year Deficiency Sec. 6662(a)
1994 $39,792 $6,921
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. All dollar amounts are rounded to the
nearest dollar.
After concessions made by petitioner, the issues for
decision are: (1) Whether petitioner has substantiated alleged
gambling losses over the amount already allowed by respondent,
entitling him to deduct such losses against his unreported
gambling winnings of $25,309; (2) whether petitioner is entitled
to deduct certain expenses claimed on Schedule C of his 1994
Federal income tax return; and (3) whether petitioner is liable
for an accuracy-related penalty under section 6662(d).
This case was submitted fully stipulated. The stipulation
of facts and the attached exhibits are incorporated herein by
this reference. Petitioner resided in Fort Lauderdale, Florida,
when the petition was filed.
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