- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011