- 2 - Addition to Tax Accuracy-Related Year Deficiency Under Sec. Penalty Under Sec. 6651(a)(1) 6662(a) 1993 $3,879 $970 $776 1994 8,627 2,157 1,725 1995 2,276 569 455 The issues remaining for decision2 are: (1) Do petitioners have unreported Schedule C gross re- ceipts for each of the years at issue in the amount determined in the notice? We hold that they do. (2) Are petitioners entitled to Schedule C deductions for each of the years at issue for “Car and truck expenses” (Schedule C car and truck expenses) in excess of the amount that respondent allowed in the notice? We hold that they are not. (3) Are petitioners required to include in income for each of the years 1994 and 1995 certain insurance proceeds that they received during each such year? We hold that they are. (4) Are petitioners entitled for any of the years at issue to a net operating loss deduction under section 172(a)? We hold that they are not. 2At trial, petitioners conceded that if the Court were to sustain respondent’s determinations with respect to Schedule C, Profit or Loss From Business (Schedule C), of petitioners’ tax return (return) for each of the years at issue, they would be liable for self-employment tax for each of those years, as determined in the notice of deficiency (notice). In that event, they would be entitled to a self-employment tax deduction for each of those years, as determined in the notice. At trial, petitioners also conceded that if the Court’s resolution of the issues remaining for decision were to result in an underpayment for any of the years at issue, they would be liable for any such year for the accuracy-related penalty under sec. 6662(a).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