- 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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