Walter R. Strohmaier - Page 3




                                        - 3 -                                         


                        OPINION OF THE SPECIAL TRIAL JUDGE                           
               COUVILLION, Special Trial Judge:  Respondent determined                
          deficiencies of $766 and $1,954 in petitioner's Federal income              
          taxes for the years 1993 and 1994, respectively.                            
               The issues for decision are:  (1) Whether petitioner is                
          entitled to a home office deduction under section 280A(c) for the           
          year 1994 in connection with his trade or business activities;              
          (2) whether petitioner is entitled, under section 162(a), for the           
          years 1993 and 1994, to deductions for car and truck expenses in            
          excess of amounts allowed by respondent; and (3) whether                    
          petitioner is entitled, under section 162(a)(2), for the years              
          1993 and 1994, to deductions for travel expenses in excess of               
          amounts allowed by respondent.2                                             
               Some of the facts were stipulated.  Those facts, with the              
          exhibits annexed thereto, are so found and are incorporated                 
          herein by reference.  At the time the petition was filed,                   
          petitioner's legal residence was Lake Wales, Florida.                       




               2At trial, petitioner conceded respondent's disallowance of            
          Schedule C meal expenses of $212 and $113, respectively, for 1993           
          and 1994.  Other adjustments in the notice of deficiency are                
          computational and will be resolved by the Court's holdings on the           
          contested issues.  These adjustments are increases in                       
          petitioner's self-employment taxes, the deduction allowable for             
          one-half of self-employment taxes, and the amounts of                       
          petitioner's earned income credit.                                          




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011