- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011