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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.
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