Michael T. Hines - Page 3

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               Respondent determined a deficiency of $9,500 in petitioner’s           
          2000 Federal income tax and an accuracy-related penalty of                  
          $1,897.  After concessions by petitioner of many items of                   
          unreported income, this Court must decide:  (1) Whether                     
          petitioner may deduct unreimbursed partnership expenses which               
          were not claimed on his individual income tax return, and (2)               
          whether petitioner is liable for the accuracy-related penalty               
          under section 6662(a).                                                      
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioner resided in Glendale, California, at the               
          time he filed his petition.                                                 
               Because petitioner has not complied with the substantiation            
          requirements of section 7491(a)(2), the burden of proof as to               
          facts relevant to the deficiency remains on petitioner.  Rule               
          142(a).  Petitioner also has the burden of proof as to liability            
          for the penalty, although respondent has the initial burden of              
          production with respect to its applicability.  Sec. 7491(c);                
          Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001).                       
               During taxable year 2000, petitioner was a general partner             
          in the partnership Hines & Hunt Entertainment (Hines & Hunt).               
          Hines & Hunt was in the business of entertainment management.               
          Petitioner was a personal manager and represented actors and                
               For taxable year 2000, Hines & Hunt filed a Form 1065, U.S.            

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