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of $673. Respondent also determined a deficiency in petitioners’
1991 Federal income tax of $13,438 and a section 6662(a) penalty
of $2,688. After concessions,2 the only substantive issue for
our consideration is whether petitioners are entitled to deduct
any of the 1990 Schedule C car and truck expenses. Petitioners
also allege that the audits and resulting deficiency
determinations were improperly conducted, and they ask that
damages be awarded for any injuries they may have suffered as a
result.
FINDINGS OF FACT3
Petitioners Richard H. and Carmen M. Strickland resided in
West Covina, California, at the time their petition was filed.
Carmen M. Strickland is a petitioner in this case because she
filed a joint return with Richard Strickland. Subsequent
references to “petitioner” refer only to Richard Strickland.
Petitioner filed his 1990 Federal income tax return on
August 26, 1991. Petitioner did not receive an extension, nor
did he offer an explanation for the late filing.
The 1990 tax return included a deduction on Schedule C for
car and truck expenses, in the amount of $8,020. Respondent
disallowed the $8,020 deduction. That disallowance, along with
2 Respondent has conceded the 1991 deficiency and related
penalty.
3 The stipulation of facts and the exhibits attached thereto
are incorporated herein by this reference.
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