- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011