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For the taxable year 1996, respondent determined a
deficiency in petitioner’s Federal income tax of $3,371, an
addition to tax under section 6654(a) of $181.49, and additions
to tax under section 6651(a)(1) and (2) of $758.47 and $370.81.
The issues for decision are: (1) Whether petitioner is
entitled to deduct a net operating loss (NOL) carryover of
$7,367.70; (2) whether petitioner is entitled to a deduction for
employee business expenses of $19,105.30; (3) whether petitioner
is liable for the addition to tax under section 6654(a); and (4)
whether petitioner is liable for the additions to tax under
section 6651(a)(1) and (2).
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Aliquippa, Pennsylvania, on the date the petition was filed in
this case.
During the year in issue, petitioner was hired as a computer
systems contract engineer with Tech-Power, Inc., located in
Minneapolis, Minnesota. Tech-Power arranged for petitioner to
provide engineering services to United Defense Limited
Partnership, also in Minneapolis, from December 11, 1995 through
April 16, 1996. Petitioner was responsible for developing
computer based training materials for United Defense. Tech-Power
issued a Form W-2, Wage and Tax Statement, to petitioner for 1996
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