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action does not relieve taxpayers of their duty to file a timely
return. See Chamberlin v. Commissioner, T.C. Memo. 2000-50.
Accordingly, we hold that Michael Friscia is liable for the
section 6651 addition to tax with respect to the net amount of tax
due on his 1995 tax return.
Issue 6. Friscia Construction’s Allowable Deductions
Respondent’s notice of deficiency denied all of Friscia
Contruction’s costs of goods sold and deductions for the taxable
year ended June 30, 1995 (the 1995 taxable year). On brief,
respondent concedes that Friscia Construction is entitled to costs
of goods sold and deductions of $108,160.
Friscia Construction claimed costs of goods sold on its 1995
taxable year corporate tax return of $222,264 along with the
following deductions:
Accounting $650
Truck expense 5,393
Misc. 111
Dues 486
Equipment rental 55
Union dues 1,204
Insurance 4,713
Office 345
Postage 64
Telephone 5,682
Utilities 1,105
Supply 1,501
Bank charges 132
Promo 430
License 96
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Total deductions 21,967
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