Randall and Lynn Bishop - Page 1

                                 T.C. Memo. 2001-82                                   

                               UNITED STATES TAX COURT                                

                       RANDALL AND LYNN BISHOP, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14129-98.               Filed April 4, 2001.                

                    P husband (H) carried on a financial planning                     
               business on behalf of individual clients.  R disallowed                
               various deductions claimed by H during 1994 on                         
               Schedule C filed with Ps’ 1994 return and also                         
               determined that Ps were subject to the sec. 6662,                      
               I.R.C., accuracy-related penalty.                                      
                    1.  Held:  R’s disallowance of various Schedule C                 
               deductions is sustained in substantial part.                           
                    2.  Held, further, no portion of R’s deduction                    
               disallowance may be treated as a disallowance of                       
               Schedule A itemized deductions rather than of                          
               Schedule C deductions.                                                 
                    3.  Held, further, R’s penalty against Ps for the                 
               whole of petitioners’ underpayment of tax for the                      
               taxable year is sustained under sec. 6662, I.R.C.                      

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