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is not reviewable by any other court, and this opinion should not
be cited as authority.
In the notice of deficiency, respondent determined the
following deficiencies in Federal income taxes and penalties
against petitioners for the years indicated:
Year Deficiency Sec. 6662(a) Penalty
1999 $2,381 $476
2000 2,604 490
The issues for decision are: (1) Whether petitioners are
entitled to certain deductions claimed on Schedule C, Profit or
Loss From Business, for the years in question in excess of
amounts allowed by respondent; (2) whether petitioners are
entitled to certain deductions claimed on Schedules E,
Supplemental Income and Loss, in excess of amounts allowed by
respondent; and (3) whether petitioners are liable for the
accuracy-related penalties under section 6662(a) for 1999 and
2000.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioners’ legal residence at the time the petition was filed
was Lynchburg, Virginia.
Petitioners are married. During the years at issue, Mr.
Viar conducted a Schedule C real estate sales activity out of
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