Michael Joseph Major - Page 2

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               The issues2 for decision are:                                          
               1.   Whether petitioner may deduct more business expenses              
          than respondent allowed for 1999 and 2000.  We hold that he may             
          not.                                                                        
               2.   Whether petitioner is liable for self-employment tax of           
          $5,339 for 1999 and $4,313 for 2000.  We hold that he is.                   
               3.   Whether petitioner is entitled to the earned income               
          credit for 1999 and 2000.  We hold that he is not.                          
               4.   Whether petitioner is liable for accuracy-related                 
          penalties under section 6662(a) for 1999 and 2000.  We hold that            
          he is.                                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Petitioner lived in Anacortes, Washington, when he filed the           
          petition.  In 1999 and 2000, he was a self-employed journalist.             
               Petitioner has six children:  Mark, Matthew, Miranda,                  
          Martin, Melanie, and Marlon.  Martin and Marlon were his                    
          dependents in 1999.                                                         
          B.   Petitioner’s 1999 and 2000 Tax Returns and Respondent’s                
               Computational Corrections to Petitioner’s Returns                      
               Petitioner timely filed Federal income tax returns for 1999            
          and 2000.  He included with each of those returns a Schedule C,             


               2 Respondent determined that petitioner is entitled to a               
          child tax credit of $1,000 on his 1999 and 2000 tax returns.                




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