Charles Shaw - Page 3

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          than respondent determined, and that respondent failed to prove             
          that his costs of goods sold were less than respondent                      
          determined.                                                                 
               3.  Whether petitioner may deduct a larger amount for                  
          business expenses than respondent allowed for each year in issue.           
          We hold that he may not.                                                    
               4.  Whether petitioner is liable for fraud under section               
          6663(a) for 1993-95.  We hold that he is not because respondent             
          did not prove by clear and convincing evidence that petitioner’s            
          gross receipts exceeded his costs of goods sold for any of the              
          years in issue.                                                             
               5.  Whether petitioner is liable for the accuracy-related              
          penalty under section 6662 for 1993-95.  We hold that he is.                
               6.  Whether petitioner is liable for the addition to tax               
          under section 6654 for failure to pay estimated tax for 1993 and            
          1994.  We hold that we lack jurisdiction to decide this issue               
          because petitioner filed returns for 1993 and 1994.                         
               7.  Whether the statute of limitations bars assessment of              
          tax for 1993.  We hold that it does not because respondent proved           
          by a preponderance of the evidence that the 6-year period to                
          assess tax applies.  Sec. 6501(3)(1)(A).                                    
               Unless otherwise specified, section references are to the              
          Internal Revenue Code as amended, and Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  






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