William Allen Simpson - Page 2




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          petitioner may deduct amounts for 1994 greater than those allowed           
          by respondent and whether petitioner is liable for the additions            
          to tax set forth above.  We hold that petitioner may not deduct             
          any greater amount and that he is liable for the additions to               
          tax.  Section references are to the Internal Revenue Code in                
          effect for the subject years.  Rule references are to the Tax               
          Court Rules of Practice and Procedure.  Dollar amounts are                  
          rounded to the nearest dollar.                                              
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated.  The stipulated facts and             
          the exhibit submitted therewith are incorporated herein by this             
          reference.  Petitioner was self-employed during 1994 as a                   
          computer engineer.  He resided in Madison Heights, Michigan, when           
          he petitioned the Court.                                                    
               Petitioner did not timely file a 1994 Federal income tax               
          return.  Respondent determined petitioner's income tax liability            
          for 1994 and issued to him a notice of deficiency reflecting that           
          determination.  Respondent later adjusted that determination to             
          take into account deductions raised and substantiated by                    
          petitioner after the issuance of the notice of deficiency.                  
          Petitioner asserts that, in addition to the deductions allowed by           
          respondent, he may deduct certain other amounts as business                 
          expenses.  Petitioner paid $3,600 to a personal acquaintance                
          (Elizabeth Helmboldt), $10,000 to his sister (Ruth Eileen                   






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