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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.
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