- 2 - Respondent determined a deficiency in, and an addition to tax under section 6651(a)(1) to, petitioner's Federal income tax for 1998 in the amounts of $5,505 and $273, respectively. The issues for decision are as follows: (1) Whether petitioner is entitled to the deductions claimed by him on his Schedule C. We hold that he is not. (2) Whether petitioner is liable for an addition to tax under section 6651(a)(1). The resolution of this issue turns on whether petitioner timely filed his income tax return for the year in issue. We hold that he did; accordingly, he is not liable for the addition to tax. The amount of petitioner’s liability for self-employment tax and the amount of the deduction under section 164(f) to which petitioner is entitled are computational matters, the resolution of which will depend on our disposition of the first of the two issues enumerated above. Background Some of the facts have been stipulated, and they are so found. At the time that the petition was filed, petitioner resided in Ceres, California. A. Petitioner’s 1998 Income Tax Return Petitioner filed Form 1040, U.S. Individual Income Tax Return, for 1998. Petitioner attached to his return Schedule C,Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011