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Respondent determined a deficiency in petitioner's Federal
income tax for 1992 in the amount of $5,115 and an addition to
tax pursuant to section 6651(a)(1) in the amount of $1,279.
The issues for decision are: (1) Whether petitioner is
entitled to Schedule C trade or business expense deductions; (2)
whether petitioner is entitled to a medical expense deduction for
amounts claimed for his special diet; and (3) whether petitioner
is liable for the section 6651(a)(1) addition to tax.2
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Colorado
Springs, Colorado, on the date the petition was filed in this
case.
Petitioner is a certified public accountant. He worked as
the chief financial officer of Gates Land Company (GLC) until he
retired in 1989. At that time, GLC was downsizing its workforce
and petitioner was suffering from complications related to
Crohn's disease. Crohn's disease is characterized by
inflammation of the lower digestive tract. Petitioner has
endured numerous surgeries and periods of hospitalization for his
Crohn's disease. In order to meet his minimum nutritional
requirements, petitioner has followed a special diet and has
2 Respondent's adjustments to petitioner's taxable Social
Security benefits, medical expense deduction (other than to the
amounts claimed for his special diet), and miscellaneous itemized
deductions are computational and will be resolved by the Court's
holding on the issues in this case.
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