T.C. Memo. 2004-108
UNITED STATES TAX COURT
PAUL D. AND GUDRUN G. WEAVER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14883-02. Filed May 3, 2004.
Petitioners included with their 1998 Federal
income tax return a Schedule C, Profit or Loss From
Business, for “Shrike Cars”. The Schedule C reflected
a net loss of $448,120, which respondent disallowed on
grounds that the costs associated with Shrike Cars were
startup expenditures within the meaning of sec. 195,
I.R.C.
Held: Petitioners are not entitled to reduce
their 1998 gross income by the $448,120 claimed net
loss derived from the Shrike Cars enterprise.
Held, further, petitioners are liable for the sec.
6651(a)(1), I.R.C., addition to tax for failure timely
to file their 1998 income tax return.
Paul D. and Gudrun G. Weaver, pro sese.
Michael J. Proto, for respondent.
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