- 2 -
Respondent determined for 2002 a deficiency in petitioner’s
Federal income tax of $3,157.88. After a concession,1 the issue
for decision is whether petitioner’s business transportation
expenses should be included on Schedule A, Itemized Deductions,
or on Schedule C, Profit or Loss from Business. At the time the
petition in this case was filed, petitioner resided in Redford,
Michigan.
This case was deemed to be submitted fully stipulated under
Rule 122, and the facts stipulated are so found.2
Background
During 2002, petitioner held two jobs, one as a commissioner
for the County of Wayne (the county), and the other as a sales
representative for West Publishing Corp. (West). During a
workday, petitioner would drive to various locations, performing
duties for both positions.
Petitioner timely filed with the Internal Revenue Service a
Form 1040, U.S. Individual Income Tax Return, for 2002.
Attached to the return were various forms including a Schedule A
and two Forms 2106, Employee Business Expenses.
1Respondent concedes that petitioner is entitled to a
deduction of $3,889 for additional State and local income taxes
and real estate taxes.
2The facts are not in dispute, and the issue is primarily
one of law. Sec. 7491, concerning burden of proof, has no
bearing on this case.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011