Alan L. Levitt - Page 3




                                        - 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.                                           




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