Emmanuel M. and Blessing N. Nwankwo - Page 3

                                       - 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