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effect for the 1999 and 2000 years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners’ Federal
income tax of $1,260 and an accuracy-related penalty of $252 for
the taxable year 1999. Respondent also determined a deficiency
in petitioners’ Federal income tax of $1,260 and an accuracy-
related penalty of $252 for the taxable year 2000.
The issues for decision are: Whether petitioners should be
allowed business expense deductions for amounts paid to their
minor children during 1999 and 2000, and whether petitioners are
liable for the section 6662(a) accuracy-related penalties for
negligence or disregard of rules or regulations in the years in
issue.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits thereto are
incorporated herein by this reference. Petitioners resided in
Des Moines, Iowa, on the date the petition was filed.
Petitioner-husband Jeffrey Allen Dumond (petitioner) appeared
before the Court and presented petitioners’ case. Petitioner-
wife Cynthia Pamela Aldridge Dumond did not appear.
Background
Petitioners timely filed their Federal income tax returns
for the taxable years 1999 and 2000. Petitioners filed their
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