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Schedule C, Profit or Loss From Business, deduction of $11,444
for the loss associated with an unincorporated venture variously
referred to as Escrow Inc. or Cool G Records (Cool G Records), or
whether that loss is nondeductible because it was incurred in an
activity not engaged in for profit within the meaning of section
183(a), (2) whether petitioner is entitled to deductions totaling
$10,338, which consist of $9,721 in unreimbursed employee
business expenses and $617 in tax preparation fees taken on
Schedule A, Itemized Deductions, (3) whether petitioner is
entitled to a deduction for a dependency exemption for her
daughter Melissa O’Donnell (Melissa), (4) whether petitioner is
entitled to head of household filing status, and (5) whether
petitioner is liable for the accuracy-related penalty under
section 6662(a).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1999, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
All dollar amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference. The facts relating to petitioner’s entitlement
to (1) a deduction for a dependency exemption for Melissa and (2)
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Last modified: May 25, 2011