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Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect during the years in
issue.
After concessions, the issues for decision are:
(1) Whether the period of limitations on assessment and
collection set forth in section 6501(a) expired as to both
of the years in issue, 1989 and 1990, before respondent
issued the subject notice of deficiency to petitioner; and
(2) whether petitioner is entitled to offset gross income
by, or to deduct as business expenses under section 162,
certain expenditures in the aggregate amount of $50,141
in 1989 and $97,854 in 1990 that respondent disallowed.
FINDINGS OF FACT
Some of the facts have been stipulated by the parties.
The Stipulation of Facts filed by the parties and the
exhibits attached thereto are incorporated herein by this
reference. Petitioner resided in Moorestown, New Jersey,
at the time he filed his petition in this case.
Petitioner graduated from Northeastern University in
1979 with a degree in business administration. He passed
the examination to become a certified public accountant
(C.P.A.) and was licensed as a C.P.A. by the State of New
York in 1980. He then worked for Arthur Anderson & Co. as
an auditor for 1 year, before matriculating at Georgetown
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