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MEMORANDUM OPINION
HALPERN, Judge: By notice of deficiency dated November 20,
1997 (the notice), respondent determined a deficiency in
petitioner’s Federal income tax for its taxable year ended
September 30, 1994 (the 1994 tax year), in the amount of $63,232
and an accuracy-related penalty in the amount of $12,646.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The parties have resolved certain issues, and issues
remaining for decision are (1) the validity of the notice,
(2) petitioner’s entitlement to certain deductions for rent,
depreciation, business meals, travel, supplies, and legal fees,
and (3) the accuracy-related penalty.
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 will not, therefore, separately set forth
our findings of fact. We will make additional findings of fact
as we proceed. Petitioner bears the burden of proof. See
Rule 142(a).
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