- 2 - Respondent determined for 1998 a deficiency in petitioners' Federal income tax of $10,338 and an addition to tax under section 6651(a)(1) of $2,434.50. The issues for decision are: (1) Whether petitioners are entitled to deductions on Schedule C, Profit or Loss From Business, in excess of those allowed by respondent; and (2) whether petitioners are subject to an addition to tax under section 6651(a)(1) for failure to file timely their 1998 Federal income tax return. Background The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. Petitioners resided in Houston, Texas, at the time the petition was filed. During the year in issue, Mr. Ferrada was employed as a contractor in the aviation industry. Petitioners also operated a food stand. 1. Mr. Ferrada's Employment In October 1997 petitioners and their son lived in Tucson, Arizona. At that time, Mr. Ferrada was hired by Global Technical Services (GTS), an Air Force subcontractor, for a position of indefinite length in Lake Charles, Louisiana. In December 1997 GTS was replaced as a subcontractor by Air Mate. Mr. Ferrada continued to work in the same position for Air Mate. In February 1998 Mr. Ferrada began working for Hi-Tec Associates, Inc. (Hi- Tec). He continued working on the same project as before but inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011