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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined deficiencies in and penalties with
respect to petitioners’ Federal income taxes as follows:
Year Deficiency Section 6662(a) Penalty
1997 $11,783 $2,356.60
1998 3,696 739.20
1999 2,310 462.00
After concessions, the following issues remain for
consideration: (1) Whether petitioners are entitled to a non-
business bad debt deduction which they claimed in 1997; (2)
whether petitioners are entitled to certain miscellaneous
itemized deductions for 1997, 1998, and 1999; (3) whether
petitioners are entitled to deductions claimed on a Schedule C,
Profit or Loss From Business (Sole Proprietorship), included with
their 1999 Federal income tax return; and (4) whether petitioners
are liable for a section 6662(a) penalty for each year in issue.
Background
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. They filed a timely joint
Federal income tax return for each year in issue. References to
petitioner are to Richard V. Frederick.
In 1996, petitioner was the sole shareholder and an employee
of the Bear Cleaning Services corporation. Through this
corporation petitioner provided services to Farm Credit. Bear
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