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I. Background
Some of the facts have been stipulated, and they are so
found. At the time that the petition was filed, petitioner
resided in Houston, Texas.
A. Petitioner’s Occupation
Petitioner filed a Form 1040, U.S. Individual Income Tax
Return, for 1999. At the bottom of page 2 of the Form 1040,
petitioner listed his occupation as “consultant” and his firm as
Americana Business Consultants.
Petitioner filed a Form 1040, U.S. Individual Income Tax
Return, for 2000. At the bottom of page 2 of the Form 1040,
petitioner listed his occupation as “accountant” and his firm as
Creative Accountants.
At trial, petitioner testified that he has a college degree
in business administration and that he regards himself as an
accountant both by education and profession.
B. Petitioner’s Schedules C
Petitioner attached a Schedule C, Profit or Loss From
Business (Sole Proprietorship), to each of his returns for 1999
and 2000. On each Schedule C, petitioner identified his business
name as Americana Business Consultants, his principal business or
3(...continued)
employment tax deduction under sec. 164(f).
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Last modified: May 25, 2011