- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011