- 2 - Respondent determined a deficiency of $5,860 in petitioner's Federal income tax for 1997 and an accuracy-related penalty under section 6662(a) of $933.40. Following concessions by the parties,2 the issues remaining for decision are: (1) Whether petitioner is entitled to a deduction for car and truck expenses in excess of that allowed by respondent in connection with a trade or business activity of petitioner known as Partners Travel; (2) whether petitioner is entitled to a depreciation/section 179 expense deduction in connection with Partners Travel in excess of that allowed by respondent; (3) whether petitioner is entitled to a $1,950 deduction for travel, meals, and entertainment expenses in connection with Partners Travel; and (4) whether petitioner is liable for the accuracy-related penalty under section 6662(a) for negligence or disregard of rules or regulations. Some of the facts were stipulated, and those facts, with the annexed exhibits, are so found and are incorporated herein by 2 Petitioner conceded that he is not entitled to claim three dependency exemptions totaling $7,950 and that he failed to report $43 in trade or business gross receipts. Respondent conceded that petitioner is entitled to Schedule C, Profit or Loss From Business, deductions for rent or lease expenses of $1,400 and utilities expenses of $180. Respondent also made partial concessions in connection with Schedule C car and truck expenses and depreciation/section 179 expense deductions. These concessions by respondent are detailed in the consideration of the relevant issues.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011