- 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