Gary Friedmann - Page 2




                                        - 2 -                                         
             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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