- 2 -
Accuracy-related
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
are:
(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.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference.
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011