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whether petitioner is liable for a penalty under section 6673.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Petitioner resided in Wayne, New Jersey, at the time that he
filed his petition.
At all relevant times, petitioner was a licensed
professional engineer receiving wages for his services.
Petitioner filed a Form 1040, U.S. Individual Income Tax Return,
for 1999 on which he reported wages of $69,041.10, taxable
interest of $2,931.49, and taxable refunds (State and local
income taxes) of $679.31. Petitioner offset his reported income
by an alleged business loss of $32,700.45 and itemized deductions
of $30,298.61. The amounts claimed on Schedule A, Itemized
Deductions, included $8,745 in employee business expenses.
On his Form 1040 for 2000, petitioner reported wages of
$79,359.94, taxable interest of $1,992.56, dividends of
$3,131.56, taxable refunds (State and local income taxes) of
$191.99, and capital gains of $8,046.01. Petitioner offset his
taxable income by a claimed business loss of $37,500 and itemized
deductions of $37,992.06, which included $8,980 in alleged
employee expenses.
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