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Respondent determined the following deficiencies, additions
to tax, and penalties with respect to petitioner’s Federal income
taxes:
Addition to Tax Penalty
Year Deficiency Section 6651(a) Section 6662(a)
1991 $4,896 $1,291.75 $979.20
1992 4,029 633.75 805.80
1993 5,382 — 1,076.40
After concessions by petitioner,1 the issues for decision are:
(1) Whether petitioner is entitled to deduct certain Schedule C,
Profit or Loss From Business, expenses in excess of amounts
allowed by respondent for the years in issue; (2) whether
petitioner is entitled to claim cost of goods sold for the
1 At trial, petitioner conceded respondent’s
determination allowing 80 percent of the car and truck expenses
for 1991, 1992, and 1993. As to the remaining 20 percent,
petitioner’s arguments will be discussed infra. Petitioner
further conceded 90 percent of respondent’s determination
disallowing some utility expenses for 1991, 1992, and 1993. As
to the remaining 10 percent, petitioner’s arguments will be
discussed infra.
The items and amounts listed below represent expenses
disallowed by respondent that were not addressed by petitioner.
As a result, petitioner is deemed to have conceded these items.
See Rules 142(a), 149; Pearson v. Commissioner, T.C. Memo. 2000-
160.
Claimed Deduction Amount
1991 1993
Rent - Vehicle — $3,734
Commissions --- 288
Insurance $46 ---
Respondent also determined that petitioner was entitled to
additional depreciation deductions of $303 and $641 in 1992 and
1993, respectively. Petitioner is deemed to have conceded these
items because she did not address these matters at trial. See
Rules 142(a), 149; Pearson v. Commissioner, supra.
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