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all Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a deficiency in petitioner's 1993
Federal income tax in the amount of $3,499 and an accuracy-
related penalty in the amount of $700 pursuant to section
6662(a).
After concessions,1 the issues for decision are: (1) Whether
petitioner is entitled to claim a Schedule C advertising expense
deduction for the 1993 tax year; and (2) whether petitioner is
liable for an accuracy-related penalty pursuant to section
6662(a) in the amount of $700 for the 1993 tax year.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in San Francisco, California.
FINDINGS OF FACT
During the year in issue, petitioner was a full-time police
officer for the City and County of San Francisco. Petitioner was
a 24-year police veteran who had been decorated four times for
valor.
In 1991, the San Francisco Police Department started a
Community Police on Patrol Program (Patrol Program) which was
designed to encourage patrol officers "to be a highly visible
1 Petitioner conceded respondent's adjustments of claimed 1993
Schedule C deductions for supplies and legal expenses.
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