David J. Edwards - Page 2




                                        - 2 -                                         
                                             Penalty                                  
               TYE Dec. 31         Deficiency     Sec. 6662(a)                        
                    1996       $540,192        $108,038                               
                    1997        511,866       102,373                                 
               After concessions by the parties, the issues for decision              
          are:                                                                        
               1.  Whether petitioner failed to report $170,619 of income             
          for 1996.  We hold he did.                                                  
               2.  Whether petitioner is entitled to deduct any portion of            
          the $278,365 that he claimed for 1996 on Schedule C, Profit or              
          Loss From Business, and that respondent disallowed.  We hold he             
          is not.                                                                     
               3.  Whether petitioner is entitled to deduct any airplane              
          expenses on Schedules C of his 1996 and 1997 tax returns.  We               
          hold  he is not.                                                            
               4.  Whether petitioner is entitled to deduct any expenses of           
          maintaining his personal residence as a trade or business under             
          sections 162(a) and 280A.  We hold he is not.                               
               5.  Whether petitioner is liable for penalties under section           
          6662(a)1 for 1996 and 1997.  We hold he is.                                 
               6.  Whether sanctions under section 6673(a) should be                  
          imposed on petitioner or his counsel.  We hold that petitioner              


               1Unless otherwise indicated, section references are to the             
          Internal Revenue Code as in effect for the years in issue, and              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  





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