- 4 - On January 10, 2002, respondent also issued a notice of deficiency to BHC in which he determined that BHC had not established that it was qualified to deduct certain claimed expenses. Respondent also determined that BHC was liable for a deficiency in its income tax, a penalty, and an addition to tax. The Basiles and BHC invoked the jurisdiction of this Court on February 5, 2002, by the timely filing of their petitions. The Basiles resided in Orefield, Pennsylvania, when their petition was filed. BHC’s mailing address was the same as the Basiles’ Orefield, Pennsylvania, address when its petition was filed. Petitioners’ representative at the time of the filings, Robert N. Bedford (Mr. Bedford), designated Tampa, Florida, as the place of trial. The Basiles’ only allegations of error in their petition are as follows: The service based their assessment upon a denial of legitimate business structures such as corporations designed to provide legal protections as provided by the law. The service also denied legitimate business deductions that are available under Code Section 162. There is also a question of any assessment at this time for 1996 because the statute of limitations has expired for that year. BHC’s only allegation of error in its petition is that “The service based their assessment upon a disallowance of certain expenses.” On April 5, 2002, respondent’s answers to the petitions were filed. Respondent denied that he erred as alleged. Respondent’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011