Leon and Mamie M. Gaither - Page 3




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          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),           










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