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Respondent determined deficiencies in petitioner’s Federal
income taxes for the taxable years 2001 and 2002 of $4,290 and
$1,188, respectively. Respondent also determined accuracy-
related penalties under section 6662(a) for the taxable years
2001 and 2002 of $858 and $237.60, respectively. The issues for
decision are: (1) Whether petitioner is entitled to deductions
for employee business expenses, and (2) whether petitioner is
liable for accuracy-related penalties under section 6662(a).
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing his
petition, petitioner resided in Medford, Massachusetts.
During the years in issue petitioner was employed by
Paychex, Inc. (Paychex), as an outside sales representative.
Paychex provided payroll services to businesses. Petitioner
sought to bring in new customers to utilize the payroll services
provided by Paychex. Petitioner’s sales territory consisted of
southeastern New Hampshire and northeastern Massachusetts.
Petitioner was responsible for 27 separate towns in this
geographic area. Paychex’s offices were located in Woburn,
Massachusetts, and petitioner resided in Sandown, New Hampshire,
during the years in issue. Petitioner’s round trip commute
between his home and office was 68.8 miles.
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