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Respondent determined a deficiency in petitioner’s Federal
income tax of $15,695, an addition to tax under section
6651(a)(1) of $3,105, and an accuracy-related penalty under
section 6662(a) of $3,139 for tax year 1994. After concessions,1
the issues for decision are: (1) Whether petitioner is entitled
to a deduction on Schedule A, Itemized Deductions, for employee
business expenses; (2) whether petitioner is entitled to various
deductions on Schedule C, Profit or Loss From Business, in excess
of the amounts allowed by respondent; (3) whether petitioner is
liable for an addition to tax under section 6651(a)(1); and (4)
whether petitioner is liable for an accuracy-related penalty
under section 6662(a).
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing his
petition, petitioner resided in Clearwater Beach, Florida.
1 Respondent determined that petitioner failed to include
Social Security income of $23,489. The increase of taxable
Social Security benefits resulted from a change in petitioner’s
adjusted gross income. This is a computational adjustment that
will be determined by the outcome of this case.
Respondent also determined that petitioner was not entitled
to a deduction of $41 for the rent or lease of vehicles,
machinery, and equipment. Petitioner did not present evidence as
to this issue. As a result, petitioner is deemed to have
conceded this issue. Rules 142(a), 149(b); Burris v.
Commissioner, T.C. Memo. 2001-49.
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