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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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Last modified: May 25, 2011