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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