- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011