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Year Deficiency Accuracy-Related Penalty
1997 $32,989 $6,597.80
1998 29,274 5,854.80
The issues remaining for decision are:2
(1) Is petitioner entitled to deduct for each of the years
at issue claimed Schedule C expenses in excess of the amount
conceded by respondent? We hold that he is not.
(2) Is petitioner liable for each of the years at issue for
the accuracy-related penalty under section 6662(a)? We hold that
he is.
FINDINGS OF FACT
Most of the facts have been deemed admitted pursuant to Rule
90(c). Certain other facts have been stipulated and are so
found.
Petitioner resided in Deer Park, Wisconsin, at the time he
filed the petition in this case.
During each of the years at issue, Minnesota Mining &
Manufacturing in St. Paul, Minnesota, employed petitioner.
During each of those years, petitioner also operated a sole
proprietorship in Hudson, Wisconsin, under the name Buck Kennel,
2In addition to the issues remaining for decision listed
below, there are other questions relating to certain determina-
tions in the notice of deficiency (notice) issued to petitioner
with respect to his taxable years 1997 and 1998 that are computa-
tional in that their resolution flows automatically from our
resolution of the remaining issues that we address herein and the
concessions of the parties.
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