Matthew P. Brown - Page 3

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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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