Kenneth G. Schladweiler - Page 2

                                        - 2 -                                         
          Year                Deficiency               penalty - sec. 66621           
          1992                $4,053                        $811                      
          1993                3,612                         722                       
          1994                4,732                         946                       
               After concessions, discussed infra, the issues for decision            
               (1)  Whether petitioner may deduct business expenses claimed           
          in connection with his trucking/hauling business in excess of               
          those allowed by respondent; and                                            
               (2)  whether petitioner is liable for the accuracy-related             
          penalty under section 6662 for each of the years at issue.                  
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts is incorporated herein by this                     
               Petitioner resided in Mitchell, South Dakota, on the date he           
          filed his petition in this case.                                            
               Petitioner timely filed his Federal income tax returns for             
          each of the taxable years 1992, 1993, and 1994.  Each return                
          contained a Schedule C, Profit or Loss From Business, reporting             
          income and expenses claimed by petitioner from the                          

               1All section references are to the Internal Revenue Code in            
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.  All monetary amounts            
          have been rounded to the nearest dollar.                                    

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