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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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