- 2 - 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 EileenPage: Previous 1 2 3 4 Next
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