- 2 - and $53,243, respectively.2 The determined deficiencies are largely attributable to respondent’s disallowance of all deductions claimed by petitioners on Schedule C, Profit or Loss From Business.3 Respondent disallowed the claimed deductions on the grounds that the expenses supporting such deductions (1) were not incurred or (2) if incurred, were not paid for ordinary and necessary business purposes. We shall grant respondent’s motion to dismiss for lack of prosecution, and we shall enter a decision against petitioners for the stated deficiencies and penalties. In light of our action, we consider it appropriate to explain the events in this case. Background On July 14, 1997, petitioners filed their petition in this case and requested that the trial be held in Phoenix, Arizona. In addition to being signed by counsel for petitioners, the petition was also executed by each petitioner individually. The address for petitioners listed therein was 8502 East Sutton Drive, Scottsdale, Arizona. 2 Respondent later revised his determination to reflect deficiencies in petitioners’ Federal income tax of $121,661 and $256,860 for 1993 and 1994, respectively, and accuracy-related penalties of $24,332 and $51,372, respectively. 3 Respondent disallowed $314,678 and $424,993 of Schedule C, Profit or Loss From Business, deductions for taxable years 1993 and 1994, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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