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After concessions by petitioner,1 the remaining issues for
decision are: (1) Whether petitioner is entitled to deduct
certain Schedule C, Profit or Loss From Business, expenses; and
(2) whether petitioner is liable for an accuracy-related penalty
under section 6662. Adjustments to the self-employment income
tax and the deduction therefor are computational and will be
resolved by the Court’s holding in this case.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Beverly Hills, California.
Petitioner is the sole proprietor of Boyd PC Consulting,
which is in the business of legal software consulting. She
started this business during the year in issue. Through Boyd PC
Consulting, petitioner created specialized macros in computer
programs, such as WordPerfect, for law firms. For example,
petitioner would install special macro functions to create
pleading form documents tailored to the client’s needs. During
1997, petitioner was also a full-time legal secretary at the law
firm Paul, Hastings & Janofsky in its Santa Monica office, and
then worked in its downtown Los Angeles office.
During the year in issue, petitioner owned a 1993 Toyota
1 At trial, petitioner conceded the disallowance of
travel and meals/entertainment expenses of $2,620 claimed on her
Schedule C, Profit or Loss From Business.
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Last modified: May 25, 2011