- 2 - Procedure. Respondent determined deficiencies in petitioners’ Federal income taxes and penalties as follows: Taxable Year Deficiency Sec. 6662(a) Penalty 2002 $4,112 $822 2003 8,562 1,712 After concessions,1 the issues for decision are: (1) Whether petitioners are entitled to claimed dependency exemption deductions for Raphael Nwankwo and Caroline Nwankwo for taxable year 2002. We hold that they are with respect to Caroline Nwankwo and are not with respect to Raphael Nwankwo. (2) Whether petitioners are entitled to claimed Schedule C, Profit or Loss From Business, deductions for legal and professional fees in the amounts of $2,850 and $1,861 for taxable years 2002 and 2003, respectively. We hold that they are entitled to deduct legal and professional fees of $105 for taxable year 2002. We hold that they are not entitled to such deductions for taxable year 2003. (3) Whether petitioners are entitled to claimed Schedule C deductions for travel expenses of $3,202 and $4,102 for taxable years 2002 and 2003, respectively. We hold that they are not. 1In the 2003 taxable year, respondent also disallowed a claimed dependency exemption for Raphael Nwankwo. At trial, petitioners conceded their error in listing Raphael Nwankwo as a dependent in 2003, as he died in August 2002. Accordingly, this exemption is no longer an issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011