Herbert C. Buck - Page 2

                                        - 2 -                                         
                 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                 
               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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