- 2 - Respondent determined deficiencies in and an addition to petitioners’ Federal income taxes as follows: Year Deficiency Sec. 6651(a)(1) 1994 $10,909 -- 1995 11,571 $2,322 1996 6,828 -- The issues for decision are: (1) Whether expenses listed on Schedule C, Profit or Loss From Business, included with petitioners’ Federal income tax return for each year in issue were incurred in an activity for profit; (2) whether income received and expenses incurred during 1994 by petitioners’ daughter are properly reportable on petitioners’ return for that year; and (3) whether petitioners had reasonable cause for failing to file a timely 1995 return. Background Some of the facts have been stipulated and are so found. Petitioners are husband and wife. They filed a joint Federal income tax return for each year in issue. At the time the petition was filed, petitioners resided in Ardmore, Alabama. References to petitioner are to Charlie Daniel Turner. Petitioner has a doctorate in aerospace engineering. At all relevant times he was employed on a full-time basis as an aerospace engineer by Nichols Research Corporation (Nichols Research). He was required to travel extensively in connection with this employment. His traveling expenses, includingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011