Vanessa K. Bernardo - Page 3

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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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