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On his 1993 Schedule C, Profit or Loss From Business (Sole
Proprietorship), for Stan’s Pawn Shop, petitioner reported a net
profit of $25,218 and deducted $29,978.80 for “Taxes and
Licenses” and $63,000 for “Cost of Labor”. Petitioner did not
report any capital gains or losses from the sale of stock or any
income from partnerships on his 1993 return. He did not attach a
Schedule E, Supplemental Income and Loss (from rental real
estate, royalties, partnerships, S corporations, estates, trusts,
REMICs, etc.), to his 1993 return. Petitioner’s spouse did not
sign the 1993 return.
E. Petitioner’s 1999 Bankruptcy Proceeding
Respondent issued a notice of deficiency to petitioner on
September 3, 1997. Petitioner filed a petition in this Court on
November 5, 1997, and an amended petition on January 2, 1998.
On March 2, 1998, respondent assessed $19,724 for
petitioner’s 1993 income taxes. On September 7, 1998, respondent
abated the $19,724 assessment, a $4,931 delinquency penalty, and
$9,899.15 in interest.
On April 8, 1999, the Tax Court calendared this case for
trial at a trial session beginning September 13, 1999.
Petitioner filed a petition in the United States Bankruptcy Court
for the Southern District of Ohio on July 30, 1999. On September
10, 1999, the Tax Court stayed proceedings in this case and
continued the case from the September 13, 1999, trial session.
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