- 2 - tax (tax), as follows: Addition to Tax Accuracy-Related Penalty Year Deficiency Under Sec. Under Sec. 6662(a) 6651(a)(1) 1992 $4,271 $417 $854 1993 7,848 1,240 1,570 The issues remaining for decision2 are: (1) Are petitioners entitled for 1993 to Schedule C deduc- tions in excess of those conceded by respondent? We hold that they are not. (2) Are petitioners liable for 1993 for the addition to tax under section 6651(a)(1)? We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioners resided in Alaska at the time the petition was filed. On April 5, 1997, petitioners signed Form 1040, U.S. Indi- vidual Income Tax Return, for 1993 (petitioners’ joint return), which respondent received on April 9, 1997. Attached to peti- tioners’ joint return was Schedule C, Profit or Loss From Busi- ness (Schedule C), in which petitioner Larry Petty (Mr. Petty) reported his principal business or profession as “Truck Service”. In Schedule C, petitioners reported gross income of $5,820 and claimed expenses of $30,268 and a net loss of $24,448. Included 2Computational issues also remain, resolution of which flows automatically from the concessions of the parties and our find- ings with respect to petitioners’ claimed Schedule C deductions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011