Gary G. Bendickson - Page 3




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          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
               Respondent determined deficiencies of $3,177, $410, and                
          $1,559 in petitioner's Federal income taxes for the years 1993,             
          1994, and 1995, respectively, and additions to tax under section            
          6651(f) of $2,597 and $2,206.50, for the years 1993 and 1995,               
          respectively.  Respondent conceded the additions to tax under               
          section 6651(f).  Respondent in the answer to Amended Petition              
          alleged that petitioner is liable for the addition to tax under             
          section 6651(a)(1) for the years 1993 and 1995 in the amounts of            
          $794.25 and $389.75, respectively, and for the penalty under                
          section 6662(a) for the years 1993, 1994, and 1995 in the amounts           
          of $635.40, $82.00, and $311.80, respectively.  Respondent has              
          the burden of proof as to those issues raised in the answer.                
          Rule 142(a).                                                                
               We must decide: (1) Whether petitioner is entitled to deduct           
          net operating losses in excess of the amounts allowed by                    
          respondent; (2) whether petitioner is entitled to deduct Schedule           
          C, Profit or Loss From Business, expenses disallowed by                     
          respondent; (3) whether petitioner is liable for the additions to           
          tax under section 6651(a)(1); and (4) whether petitioner is                 
          liable for the penalties under section 6662(a).                             









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