Richard Henry and Carmen M. Strickland - Page 2




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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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