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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.
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Last modified: May 25, 2011