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Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect for the year in issue
and all Rule references are the Tax Court Rules of Practice
and Procedure.
The issues for decision in this case involve
petitioners’ return for 1993. After concessions, the
issues are: (1) Whether petitioners are entitled to deduct
the Schedule C expenses claimed on their return in the
aggregate amount of $34,750 or the expenses allegedly
proven at trial in the aggregate amount of $39,403; (2)
whether petitioners are liable for the accuracy-related
penalty under section 6662(a); and, (3) whether petitioners
are liable for an addition to tax under section 6651(a)(1).
Petitioners have prosecuted other cases before this
Court. Their return for 1992 is the subject of King v.
Commissioner, T.C. Memo. 1998-69, and their return for 1994
is the subject of King v. Commissioner, T.C. Memo. 1999-
293.
FINDINGS OF FACT
Petitioners are husband and wife who filed a joint
individual tax return for 1993. At the time they filed the
petition in this case, petitioners resided in Wyndmoor,
Pennsylvania. In this opinion, references to petitioner
are to Mr. Fatai O. King.
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