- 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 repliedPage: 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