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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined the following
deficiencies and penalties with respect to petitioner’s Federal
income taxes:
Penalty
Year Deficiency Sec. 6662, I.R.C.
1997 $28,565 $5,713.00
1998 43,789 8,757.80
1999 15,216 3,043.20
The principal issues for decision are:
(1) Whether petitioner is entitled to business expense
deductions claimed on Schedules C, Profit or Loss From Business,
for the taxable years 1997, 1998, and 1999; and
(2) whether petitioner is liable for the section 6662
accuracy-related penalty for the subject years.1
In the notice of deficiency, respondent also disallowed in
full unreimbursed employee business expenses claimed by
petitioner on Schedule A, Itemized Deductions, for 1999. Neither
party specifically addressed this matter at trial or on brief.
Such items are typically deemed conceded. See Rules 149(b),
151(e)(4) and (5); Levin v. Commissioner, 87 T.C. 698, 722-723
(1986), affd. 832 F.2d 403 (7th Cir. 1987). To the extent that
anything in petitioner’s brief could be interpreted to pertain to
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011