Kevin P. Osborne - Page 2




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               The issues for decision are:  (1) Whether petitioner is                
          entitled to deductions for “business promotion” expenses in                 
          excess of the amounts allowed by respondent; (2) whether                    
          petitioner is entitled to deduct amounts representing the                   
          repayment of loan principal; and (3) whether petitioner is liable           
          for the penalties under section 6662(a).1                                   
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in               
          Burlingame, California, on the date the petition was filed in               
          this case.                                                                  
               Petitioner is an insurance broker and operates a business              
          named Osborne Insurance Agency.  The business is operated as a              
          sole proprietorship; there is no legal entity separate from                 
          petitioner himself, such as a corporation, limited liability                
          company, or partnership.  Petitioner filed a Schedule C, Profit             
          or Loss from Business, in each of the years in issue for the                
          business.                                                                   
               The first issue for decision is whether petitioner is                  
          entitled to deductions for “business promotion” expenses in                 
          excess of the amounts allowed by respondent.                                


          1Petitioner concedes respondent’s adjustments to his                        
          deductions for taxes and licenses.  Respondent’s adjustments to             
          the amounts of self employment income tax, and the deductions               
          therefor, are computational and will be resolved by the Court’s             
          holding on the issues in this case.                                         




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Last modified: May 25, 2011