- 3 -
automobile and travel and meals and entertainment expense
deductions; (7) whether petitioners are entitled to claim for
1994 an additional expense under section 179 for a depreciable
asset; and (8) whether there is underpayment of petitioners’ tax
due to negligence.
Some of the facts have been stipulated. Stipulated facts
and accompanying exhibits are incorporated herein by reference.
FINDINGS OF FACT
Petitioners resided in Lisle, Illinois, at the time the
petition was filed in this case.
During the years at issue and at the time of trial, Mrs.
Reynolds was a manager for Service America Corp., and petitioner
was a supervisory internal revenue agent. Petitioner has been an
employee of the Internal Revenue Service (IRS) since 1976.
Before his employment with the IRS, petitioner was an electronics
engineer with the Department of Defense. Petitioner also holds a
certified public accountant’s license from the State of South
Carolina, is a 1982 graduate of the Indiana University Law
School, and was licensed as an attorney by the State of Illinois
in 1985.
Petitioner prepared the joint individual Federal income tax
returns for himself and his wife for 1993 and 1994.
In April of 1998, a year after respondent issued the
statutory notice of deficiency in this case, respondent replied
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011