- 2 - Respondent determined a $2,263 deficiency in petitioners’ Federal income tax for 2002 and a $453 accuracy-related penalty under section 6662(a). After concessions by the parties,1 the issues for decision are: (1) Whether petitioners’ gross income includes $15 of wage income from Farmers Insurance Group (Farmers); (2) whether petitioners’ gross income includes $3,845 of self-employment income from Metropolitan Property and Casualty Insurance Company (MetLife); and (3) whether petitioners are liable for an accuracy-related penalty under section 6662(a). Background Some of the facts have been stipulated, and they are so found. The stipulation of facts and the supplemental stipulation of facts with attached exhibits are incorporated herein by this reference. Petitioners Tunji Mabinuori (Mr. Mabinuori) and Christina Mabinuori (Mrs. Mabinuori) are married and resided in Springfield, Oregon, when their petition was filed. Unless otherwise indicated, all references to petitioner are to Mr. Mabinuori. 1. Petitioner’s Involvement With Farmers 1 Petitioners concede they received and failed to report a $1,844 State income tax refund. Petitioners assert in the petition that they are entitled to deductions for “business mileage” that were not claimed on their 2002 joint Federal income tax return; however, petitioners did not pursue this argument at trial, and we therefore consider the argument abandoned. See Nicklaus v. Commissioner, 117 T.C. 117, 120 n.4 (2001); Korchak v. Commissioner, T.C. Memo. 2005-244 n.6. For convenience, we address the parties’ additional concessions infra. Adjustments not addressed herein are computational.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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