Craig D. Hollingsworth - Page 3




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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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