- 2 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011