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(2) whether petitioner is entitled to deduct additional
expenses in 2001;
(3) whether petitioner is liable for the 10-percent
additional tax on his Individual Retirement Account (IRA)
distribution under section 72(t)(1); and
(4) whether petitioner received $17 of interest from the
Commonwealth of Virginia in 2001.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Knoxville, Tennessee, at the time that he
filed his petition.
Petitioner was employed as a computer software consultant
by Metamor Enterprise Solutions, Inc. (Metamor), until his
position was eliminated and he was discharged on March 30, 2001.
While working for Metamor, petitioner traveled from his home to
temporary client sites to make sales presentations to businesses
regarding computer software, prepare proposals for implementation
of the software for the business, and, if it was purchased,
implement the computer software. At times, petitioner’s job with
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