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Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined deficiencies of $4,586 and $3,929 in
petitioners’ 2000 and 2001 Federal income taxes, respectively.
After concessions by petitioners,1 the issue for decision is
whether petitioners are entitled to expense deductions in the
taxable years 2000 and 2001 related to a sole proprietorship.
Background
These two cases were consolidated for purposes of trial,
briefing, and opinion. 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, as well
as an additional exhibit admitted during trial, are incorporated
herein by this reference. Petitioners Gunasundran R. Pillay (Mr.
Pillay) and Kalaivani Govender are married and resided in Citrus
Heights, California, when the petition in each docket was filed.
Unless otherwise indicated, all references to petitioner are to
Mr. Pillay.
1 Petitioners concede that a $1,175 State income tax refund
they received in 2001 is taxable. Petitioners also concede
certain expense deductions claimed on their Schedule C, Profit or
Loss From Business, which are discussed infra. The remaining
adjustments in the notices of deficiency are computational;
therefore, we do not address them.
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Last modified: May 25, 2011