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Respondent determined a deficiency in petitioners’ Federal
income tax of $5,277 for the taxable year 1996. The sole issue
for decision is whether petitioners are entitled to numerous
business expense deductions disallowed by respondent.1
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. Petitioners resided in
Ukiah, California, on the date the petition was filed in this
case.
During taxable year 1996, petitioners had combined wage and
salary income of $67,571. Petitioner husband (petitioner) was
employed full time as a professor of physics and astronomy at
Mendocino College and part time as a professor of astronomy at
Santa Rosa Junior College. Petitioner wife was employed full
time as a crisis counselor at Jefferson Elementary School in
Cloverdale, California.
Petitioners filed a joint Federal income tax return for
taxable year 1996. They filed with the return a Schedule C,
Profit or Loss From Business. The schedule listed petitioner as
1Respondent’s adjustments to petitioners’ itemized
deductions, self-mployment income tax, and self-employment income
tax deduction are computational and will be resolved by our
holding on the issue in this case. We note that respondent
previously corrected two mathematical or clerical errors with
respect to petitioners’ itemized deductions. The increase in the
tax shown on the return resulting from this correction has been
assessed and paid and is not at issue in this case.
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