- 2 - decision are: (1) Whether petitioners failed to report $14,555 of Schedule C, Profit or Loss From Business, income for the 1994 tax year; (2) whether petitioners are entitled to deduct $2,035 for travel expenses and $1,330 for meals under section 162 as Schedule C business expenses; and (3) whether petitioners are liable for the accuracy-related penalty under section 6662(a).2 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and the related exhibits are incorporated herein by this reference. At the time of filing the petition in this case, petitioners resided in Irvine, California. (...continued) their landscaping business. They dispute, however, that this income is subject to tax. Respondent also determined that petitioners had overstated their Schedule C, Profit or Loss From Business, deductions relating to their landscaping business by $18,456. Respondent, however, conceded $2,235 of these deductions, reducing the overstated amount to $16,221. Petitioners then conceded $12,856 of that amount, leaving $3,365 in dispute. Before the parties’ concessions, respondent determined that petitioners were subject to additional self-employment income taxes of $6,908 and entitled to an additional self-employment tax deduction of $2,558. Petitioners presented no evidence at trial regarding this issue and failed to address it on brief. Petitioners are therefore liable for any self-employment income taxes due on the additional self-employment income found by the Court. See Petzoldt v. Commissioner, 92 T.C. 661, 698 (1989). 2 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011