- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011