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accuracy-related penalty under section 6662(a) in the amount of
$5,785.60.2
After concessions, the issues for decision3 are: (1)
Whether petitioner’s leasing activity was a trade or business;
(2) whether petitioner’s losses constitute nondeductible passive
losses under section 469; (3) whether petitioner substantiated
deductions claimed on his Schedule C, Profit or Loss From
Business; (4) whether petitioner is liable for an addition to tax
for failing to timely file his 1993 Federal income tax return;
and (5) whether petitioner is liable for the accuracy-related
penalty under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. Petitioner is a cash
method taxpayer who resided in Fall City, Washington, at the time
he filed his petition.
Petitioner is a scientist with an M.S. degree in solid state
devices and a Ph.D. degree in ultrasonic and semiconductor device
2All subsequent references to monetary amounts are rounded
to the nearest dollar.
3The notice of deficiency contains adjustments to
petitioner’s itemized deductions and statutory exemption
allowance for the year in issue. These are computational
adjustments which will be resolved by the outcome of the issues
to be decided, and we do not separately address them.
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