Andy Rataiczak - Page 2




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          Unless otherwise noted, all section references are to the                   
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               We must decide the following issues:  (1) Whether petitioner           
          had unreported income.  We hold that he did, to the extent                  
          provided below.  (2) Whether petitioner is entitled to a                    
          depreciation deduction for towing equipment for each of the years           
          in issue.  We hold that he is.  (3) Whether petitioner is liable            
          for an addition to tax under section 6651(a).  We hold that he              
          is.  (4) Whether petitioner is liable for accuracy-related                  
          penalties under section 6662(a).  We hold that he is not.                   
               Some of the facts have been stipulated and are so found.  We           
          incorporate by this reference the stipulation of facts and                  
          attached exhibits.  At the time of filing the petition,                     
          petitioner resided in Quaker City, Ohio.                                    
               From March 1990 to September 1994, petitioner operated a               
          service station in Barnesville, Ohio.  The station had four                 
          gasoline pumps, a diesel and kerosene pump, and two service bays.           
          In addition to fuel sales, petitioner sold miscellaneous items              
          such as chips, candy, soda pop, and tobacco.  Also, petitioner              
          sold and installed tires and other auto parts in connection with            
          the station’s service and repair business.  Petitioner closed the           
          service station in September 1994 because he was unable to make a           






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