- 2 -
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge: Respondent determined a
deficiency of $5,977 in petitioners' Federal income tax for 1995
and a section 6651(a)(1) addition to tax of $219.60. Unless
otherwise indicated, section references are to the Internal
Revenue Code in effect for the year in issue, and Rule references
are to the Tax Court Rules of Practice and Procedure.
Respondent, in an answer to the amended petition filed
herein, claims an increased deficiency of $12,030 and an
increased section 6651(a)(1) addition to tax of $522 for 1995.
The parties have stipulated that petitioners incurred at least
$2,890 in advertising and telephone expenses deductible under
section 162(a) which relate to the locksmith business of Bruce
Krist (petitioner).
We must decide: (1) Whether petitioners are entitled to
deduct the remaining disallowed Schedule C expenses of $19,976
($22,866 total disallowed minus $2,890) for the locksmith
business; (2) whether petitioners had $19,640 of unreported
income for 1995 in the form of unexplained bank deposits; (3)
whether petitioners had $14,093 of additional unreported income
in the form of unexplained bank deposits, an issue raised for the
first time on brief; (4) whether petitioners are entitled to a
casualty loss of $15,800 for the seizure and destruction of the
guns held for their alleged firearms business; and (5) whether
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011