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of $4,454 for 1999. After concessions,2 the issues for decision
are: (1) Whether Adrian D. Troutman, Jr. (petitioner), is
entitled to a deduction pursuant to section 162(a)(1) for alleged
additional compensation paid to his employee;3 and (2) whether
petitioner is entitled to a deduction for costs associated with
the construction of a logging road on his property.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Winlock, Washington.
During 1999, petitioner operated three sole proprietorships:
T-Foil Enterprises, A & J Insulation Contractors (Washington),
and A & J Insulation Contractors (Oregon). T-Foil Enterprises
manufactured insulation, while A & J Insulation Contractors
installed the insulation manufactured by T-Foil Enterprises. The
insulation manufactured by T-Foil Enterprises was also sold to
third parties.
2 Respondent has conceded all issues identified in the
notice of deficiency for 1999 and allowed a previously unclaimed
deduction for a charitable contribution of $6,405 for 1999.
3 This issue was not included in the statutory notice of
deficiency or in the petition. We find that the issue was tried
by consent pursuant to Rule 41(b)(1), and we consider it to be
before the Court.
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Last modified: May 25, 2011