- 2 - hearing, and we conclude that a hearing is not necessary. Rule 232(a)(3). We decide the matter before us based on the record. In a statutory notice of deficiency dated November 1, 1994, respondent determined a deficiency in petitioners' 1992 Federal income tax in the amount of $7,888 and an accuracy-related penalty pursuant to section 6662 in the amount of $1,578. In the notice of deficiency, respondent disallowed the following expenses claimed by petitioners on their 1992 return on the ground that petitioners had not substantiated the claimed deductions: Schedule C Auto expenses* $7,583 Schedule C Supplies** 4,639 Schedule C Travel 1,745 Schedule C Meals and entertainment 1,289 Schedule E Expense 10,908 Schedule E Depreciation 4,505 Schedule A Taxes 565 * This amount consists of auto expenses of $3,743 from Primerica Schedule C and commissions of $3,840 from the Product Wholesale Distribution Schedule C. ** This amount consists of $2,886 for supplies claimed on the Primerica Schedule C and $1,753 for supplies claimed on Product Wholesale Distribution Schedule C. Respondent also increased a $5,248 tax on an early distribution reported by petitioners on their return to $6,268, resulting in an upward adjustment of $1,020. Petitioners timely filed their petition on January 30, 1995, in which they disagreed with each of respondent's above-mentioned adjustments. After the petition was filed, the case was assigned to an Appeals officer in Tampa, Florida. Because the principal issuePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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