- 2 - Respondent determined a deficiency in petitioner’s Federal income tax of $23,243 and a penalty under section 6662(a) of $4,648.60 for 1996. After a concession by respondent,1 the issues for decision are: (1) Whether $37,828 reported by Joyce Sams, Inc. (Sams, Inc.), on Form 1120S, U.S. Income Tax Return for an S Corporation, is taxable to petitioner; (2) whether petitioner received unreported income of $25,578; (3) whether petitioner is entitled to deduct expenses of $13,2792 on her individual return that were claimed by Sams, Inc. and disallowed by respondent; (4) whether petitioner is entitled to a claimed loss on Schedule E, Supplemental Income and Loss, of $3,287; (5) whether petitioner is entitled to claimed Schedule E deductions of $1,246; (6) whether petitioner is entitled to the claimed net operating loss (NOL) carryover of $56,699; (7) whether petitioner is entitled to the standard mileage deduction for business miles traveled; and (8) whether petitioner is liable for an accuracy- related penalty under section 6662. Respondent also determined that petitioner is subject to self-employment tax and to the alternative minimum tax. These adjustments are computational and dependent on the adjustments to income. Therefore, we need not separately address these issues. 1 Respondent conceded $9,740 of the original adjustment of $35,318 of unreported income. 2 Sams, Inc. deducted $35,866 of expenses on its return of which respondent disallowed $13,279.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