- 2 -
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are:1 (1) Whether petitioner is
entitled to deduct Schedule C, Profit or Loss From Business,
expenses in excess of the amounts allowed by respondent, (2)
whether petitioner is liable for an addition to tax pursuant to
section 6651(a)(1) for 1993, and (3) whether petitioner is liable
for penalties pursuant to section 6662(a) for 1993, 1994, and
1995.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition, Carroll R. Furnish resided in West Palm Beach, Florida.
Mr. Furnish built the house that he lived in with his two minor
children with “his own hands”. During the years in issue, he
owed 2 years of property taxes on his home, and he “maxed out”
all his credit cards.
Prior to and during the years in issue, Mr. Furnish was in
1 Adjustments respondent made to petitioner’s earned income
credit, deduction for personal exemptions, and self-employment
tax are computational in nature and will be resolved by our
holdings herein.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011