Joyce H. Sams - Page 3




                                        - 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.                                        




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