Ilya G. and Sophia K. Margolis - Page 2




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               Respondent determined a deficiency in petitioners' Federal             
          income tax for 1992 in the amount of $4,141, as well as an                  
          accuracy-related penalty under section 6662(a) in the amount of             
          $828.  At trial, respondent asserted an increased deficiency and            
          accuracy-related penalty in the amounts of $6,393 and $1,278,               
          respectively.  As discussed in further detail in this opinion,              
          petitioners concede a portion of the increased deficiency.                  
               After concessions by the parties, the issues for decision              
          are:                                                                        
               (1)  Whether petitioners failed to report self-employment              
          income in the amount of $16,727.  We hold that petitioners failed           
          to report $14,191 of self-employment income.2                               
               (2)  Whether petitioners are entitled to certain Schedule C            
          deductions.  We hold that they are to the extent provided in the            
          opinion.                                                                    
               (3)  Whether petitioners are liable for the accuracy-related           
          penalty under section 6662.  We hold that they are to the extent            
          provided in the opinion.                                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and are so found.              
          Petitioners resided in Charlotte, North Carolina, at the time               
          that their petition was filed with the Court.                               


          2  The disputed amount of unreported self-employment income                 
          is in addition to $14,180 of unreported self-employment income              
          conceded by petitioners to have been received by Mrs. Margolis.             



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