- 5 - Respondent mailed a notice of deficiency to petitioner on June 18, 1999. Respondent disallowed the attorney’s and accounting fees deduction claimed on Schedule A and also disallowed all of the claimed deductions on Schedule C for BHTC, on the basis that petitioner failed to establish that he paid or incurred the expenses, and that the expenses were not ordinary and necessary to his business. Respondent also determined that petitioner was liable for the addition to tax under section 6651(a)(1) and the accuracy-related penalty under section 6662(a). Discussion A. General At the time of filing the petition, petitioner filed a Designation of Place of Trial, designating Tampa, Florida. By notice dated February 3, 2000, this case was set for trial at a Tampa, Florida, trial session of this Court scheduled to commence on April 24, 2000. On March 31, 2000, petitioner filed a Motion to Continue Trial Generally, which was granted. By notice dated December 8, 2000, this case was again set for trial at a Tampa, Florida, trial session scheduled to commence February 26, 2001. A few days before the February 26, 2001, trial calendar, the Court held a teleconference with petitioner and respondent. Petitioner requested that the trial be continued. Petitioner asserted that he had moved to Las Vegas and was unable to appearPage: 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