- 3 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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