Paul F. and Barbara J. Basile - Page 4

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               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’s           





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