Claude D. Mayo, Sr. and Lessie M. Mayo - Page 3

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               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 7463 of the Internal Revenue Code in           
          effect at the time the petition was filed.1  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 petitioners’ 1995 and            
          1996 Federal income taxes of $5,940 and $5,354, respectively.               
          Respondent also determined that petitioners are liable for                  
          negligence penalties under section 6662(a) for 1995 and 1996 of             
          $1,188 and $1,070.80, respectively.                                         
               The issues are whether petitioners are (1) entitled to                 
          deduct losses on Schedule C, Profit or Loss From Business, for              
          the years in issue arising from a used-car activity of petitioner           
          Claude D. Mayo, Sr. (petitioner); (2) entitled to deduct greater            
          medical and mortgage interest expenses than the amounts allowed             
          by respondent; and (3) liable for the negligence penalties under            
          section 6662(a) for 1995 and 1996.  At the time the petition was            
          filed petitioners resided in Moneta, Virginia.                              
               The relevant facts may be summarized as follows.  During               
          1995 and 1996 petitioners reported income from interest,                    




          1    Unless otherwise indicated, subsequent section references              
          are to the Internal Revenue Code in effect for the years in                 
          issue, and Rule references are to the Tax Court Rules of Practice           
          and Procedure.                                                              




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