Larry M. Petty and Jean L. Petty - Page 2




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          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.            





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