Peter and Mary Possas - Page 3




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          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               Respondent determined deficiencies in petitioners’ Federal             
          income taxes of $7,297 in 1995 and $8,355 in 1996 and section               
          6662(a) accuracy-related penalties of $1,459.40 and $1,646,                 
          respectively.  After concessions by both parties,1 the issues for           
          decision are:  (1) Whether petitioners received unreported income           
          of $8,355 in 1996; (2) whether petitioners are entitled to the              
          claimed deductions for advertising expenses in 1995 and 1996; and           
          (3) whether petitioners are liable for accuracy-related penalties           
          for 1995 and 1996 under section 6662(a).                                    
               Some of the facts have been stipulated and are so found.               
          Petitioners resided in Odessa, Florida, at the time they filed              
          their petition.                                                             
                                     Background                                       
               Petitioner Peter Possas (Mr. Possas) worked as a manager at            
          a Nissan automobile dealership during the years at issue.  His              
          wages in 1995 totaled $108,867.57 and in 1996 totaled $92,657.87.           
          Mr. Possas paid for flyers to advertise the automobile                      
          dealership.  The dealership had advanced him money to pay for a             


               1  Respondent conceded the claimed employee business expense           
          deduction for 1995 of $5,156.60.  Respondent conceded that                  
          petitioners did not have unreported income in 1995.  Petitioners            
          conceded receipt of a taxable award from Mr. Possas’s employer in           
          1996 of $2,637.  Petitioners conceded that they were not entitled           
          to a deduction for the “unidentified expenses” claimed on their             
          1995 return of $8,532.                                                      




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