- 2 - decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority. Respondent determined deficiencies in petitioners’ Federal income taxes, additions to tax, and penalties as follows: Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $11,354 $1,555 $2,271 1993 11,041 1,364 2,208 1994 10,646 521 2,129 The issues for decision for each year in issue are: (1) Whether petitioners are entitled to various trade or business expense deductions; (2) whether petitioners had reasonable cause for failing to file a timely Federal income tax return; and (3) whether the underpayment of tax required to be shown on petitioners’ Federal income tax return is due to negligence. Background Some of the facts have been stipulated and are so found. Petitioners are husband and wife. They filed a joint Federal income tax return for each year in issue. At the time the petition was filed, petitioners resided in Jacksonville, Florida. References to petitioner are to Leon Gaither. During the years in issue, petitioner was the sole proprietor of Gaither and Associates (G&A). He was also the sole shareholder of Professional Services of Jacksonville, Inc. (PSI),Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011