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Respondent determined deficiencies in petitioner’s Federal
income taxes of $6,513 and $5,753 for the taxable years 2000 and
2001, respectively. Additionally, respondent determined an
addition to tax of $654 pursuant to section 6651(a) for the
taxable year 2000.
After concessions,1 the issue still in dispute is whether
petitioner’s stipulated truck expenses of $12,757 and $12,657 for
taxable years 2000 and 2001, respectively, should be reported on
petitioner’s Schedule A, Itemized Deductions, and therefore be
subject to the 2-percent floor of section 67, or whether such
expenses were a result of an independent trade or business and
therefore should be reported on a Schedule C, Profit or Loss From
Business.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
1At trial, the parties agreed: (1) With respect to the 2000
tax year, petitioner is entitled to an itemized deduction for
unreimbursed employee business expenses of $24,921, which is
subject to the 2-percent floor of sec. 67; (2) with respect to
the 2001 tax year, petitioner is entitled to an itemized
deduction for unreimbursed employee business expenses of $23,487,
which is subject to the 2-percent floor of sec. 67; (3) with
respect to the 2000 tax year, petitioner substantiated truck
expenses of $12,757; (4) with respect to the 2001 tax year,
petitioner substantiated truck expenses of $12,657; and (5) that
petitioner’s 2000 Federal income tax return was delinquent and
thus petitioner is liable for the addition to tax of $654
pursuant to sec. 6651(a).
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