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be cited as authority.
Respondent determined a deficiency of $13,267 in
petitioners’ Federal income tax and an accuracy-related penalty
under section 6662(a) of $2,653, for the year 2000. After
concessions, the sole issue for decision is whether petitioners
had unreported gross income of $51,470 from a trade or business
activity in 2000.2
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and are made part hereof.
Petitioners’ legal residence at the time the petition was filed
was Virginia Beach, Virginia.
Petitioners were married during the year at issue and filed
a timely joint income tax return. Harry Hall was a truck driver.
He conducted this occupation as a Schedule C, Profit or Loss From
Business, trade or business activity. Evelyn Hall worked in
maintenance and reported $15,968 in wage and salary income.
Mr. Hall operated a tractor-trailer. He owned the tractor
and leased the trailer from American Road Lines (ARL), a private
corporation with whom he had a contractual relationship during
the year at issue. ARL had contracts with the Federal
2 Petitioners conceded the sec. 72(t) tax due on an early
withdrawal from an Individual Retirement Account (IRA).
Respondent conceded the accuracy-related penalty and $10,983 in
additional allowable Schedule C expenses. Other adjustments are
computational in nature.
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