- 2 - 1994. Petitioner filed a petition seeking a redetermination of the deficiency and contesting his liability for the penalty. Following concessions,2 the issues for decision are: (1) Whether petitioner may deduct Schedule C, Profit or Loss From Business, expenses in excess of those conceded by respondent; and (2) whether petitioner is liable for the accuracy-related penalty. Background Prior to trial, the parties filed a “stipulation of facts”, which did little more than outline the factual disputes remaining for trial and provide to the Court various written summaries of petitioner’s litigating positions, and a supplemental stipulation of facts. To the extent that the stipulations reflect agreement regarding material facts, those facts are summarized below and are found accordingly. Petitioner resided in Henderson, Nevada, at the time he filed his petition in this case. In March 1994, petitioner’s employer, Mattel, terminated petitioner’s employment. At that time, petitioner, who had more than 20 years of manufacturing experience in the toy industry, 2Respondent also proposed adjustments for a State tax refund that petitioner allegedly received and to petitioner’s exemptions and itemized deductions. The parties agree that petitioner is not required to include any State tax refund in income and that the remaining adjustments are computational.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011