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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,
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