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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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Last modified: May 25, 2011