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than at the respective junior colleges where he taught.
Commissioner v. Soliman, 506 U.S. 168, 175 (1993)("principal
place of business" means not merely an important or necessary
place of business, but the most important one); Puckett v.
Commissioner, T.C. Memo. 1990-89.
The Court holds that petitioner is not entitled to any
deductions related to his employment as a part-time temporary
junior college professor in excess of those allowed by
respondent.
Timeliness of the Return
Respondent determined an addition to tax under section
6651(a)(1) for petitioners' failure to file timely a Federal
income tax return for 1995. In the stipulation of facts signed
by the parties, it is stated that "Petitioners timely filed a
U.S. Individual Income Tax Return, Form 1040, for 1995" and that
a "true and correct copy of this return is attached hereto as
Joint Exhibit 1-J."
The return attached to the stipulation and represented to be
true and correct is dated as signed by petitioners on April 14,
1998, 2 years after the due date of the return. During trial,
petitioner identified his signature and agreed that it was dated
when he signed it. The face of the return bears an IRS date
stamp indicating that it was received on April 17, 1998.
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