- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011