- 2 - Michael G. Moore, for petitioners. Nancy L. Spitz, for respondent. MEMORANDUM OPINION HALPERN, Judge: By notice of deficiency dated May 13, 1998 (the notice), respondent determined a deficiency in petitioners’ Federal income tax for 1994 in the amount of $58,632 and an accuracy-related penalty in the amount of $11,726.40. Petitioners have conceded certain of respondent’s adjustments giving rise to that deficiency. The issues remaining for decision are (1) certain adjustments by respondent to deductions claimed by petitioners for depreciation, office expenses, rental expenses, and expenses for meals and entertainment, (2) certain ancillary consequences of respondent’s adjustments, and (3) petitioners’ liability for the accuracy-related penalty.1 Some facts have been stipulated and are so found. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. We need find few facts in addition to those stipulated and shall not, therefore, separately set forth our findings of fact. We shall make additional findings of fact 1 The deficiencies also reflect adjustments to petitioners’ itemized deductions, personal exemptions, the credit for self- employment taxes, and the sec. 164(f) deduction for one-half of self-employment taxes, all of which derive from the principal adjustment and are not directly disputed by petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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