- 2 -
are to the Internal Revenue Code in effect for the year at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Shortly before the scheduled trial date, respondent filed a
motion to dismiss pursuant to Rule 53 alleging that petitioners
failed to properly prosecute their case. The motion was taken
under consideration, and the trial proceeded on the merits.
The issues for decision are: (1) Whether petitioners are
entitled to amounts reported for returns and allowances, costs of
goods sold, and business expense deductions on four separate
Schedules C, Profit or Loss From Business, for the year at issue;
(2) whether petitioners are liable for an addition to tax of
$2,651.25 pursuant to section 6651(a)(1); and (3) whether
petitioners are liable for a penalty of $2,180.80 pursuant to
section 6662(a).
FINDINGS OF FACT
The attached exhibits are incorporated herein by this
reference. At the time the petition was filed, petitioners
resided in Missouri City, Texas.
Petitioners Cedric K. Nunn (Mr. Nunn) and Madelyn D. Nunn
(Mrs. Nunn) are husband and wife. For the year at issue, Mr.
1(...continued)
as a small tax case. See sec. 7463. On Oct. 22, 2001, pursuant
to petitioners’ oral motion to have the case changed from a small
tax case to regular case status, the “S” designation was removed.
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