- 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