- 2 -
related penalty, pursuant to section 6662(a),1 of $6,402 for
2000.
The issues for decision2 are:
(1) Whether petitioner is entitled to the deductions he
claimed on Schedule C, Profit or Loss From Business, of his 2000
return; and
(2) whether petitioner is liable for the accuracy-related
penalty under section 6662(a).
Background
Petitioner resided in Anaheim, California, when his petition
in this case was filed.
During 2000, petitioner was a trucker who worked both as a
union employee and as an independent contractor for Consolidated
Freightways, a trucking company. Consolidated Freightways
permitted its employees to maintain records in an office at the
end of its loading dock, and petitioner kept his business records
there throughout 2000. Petitioner testified that he used these
records in the preparation of his 2000 Federal income tax return.
1All section references are to the Internal Revenue Code in
effect for the taxable year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure. All monetary
amounts are rounded to the nearest dollar.
2Respondent also determined an increase in petitioner’s
self-employment tax. The adjustment is computational and turns
on our resolution of the Schedule C deduction issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011