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claimed on the Schedules C, Profit or Loss From Business, for
each of the years at issue greater than those deductions allowed
by respondent on either Schedule C or Schedule A, Itemized
Deductions, and (2) liable for the section 6662(a) accuracy-
related penalty for 1997.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
At the time the petition was filed, petitioner resided in
Bethlehem, Pennsylvania.
Background
During the years at issue, petitioner was employed as a
full-time professor of physics at Lehigh University. Petitioner
earned a B.A. and an M.S. in physics and a Ph.D. in experimental
particle and nuclear physics from the University of Pennsylvania.
During the years at issue, petitioner owned property at 30 East
3d Street in Bethlehem, Pennsylvania (the Bethlehem property), an
apartment in Mt. Pocono, Pennsylvania, and an apartment in North
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