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Respondent determined a $7,073 deficiency in petitioners’
2002 income tax and a $1,414.60 accuracy-related penalty pursuant
to section 6662(a). After concessions,1 the issues for decision
are: (1) Whether petitioners can deduct (a) $246 for charitable
cash contributions, (b) $24,510.89 of other expenses, (c) $55 of
bad debt expense, and (d) $3,506 for home office expense; and (2)
whether petitioners are liable for an accuracy-related penalty
under section 6662(a).
Some of the facts have been stipulated and are so found.
Petitioners Samuel Pinkney and Laura Pinkney are married and
resided in Los Angeles, California, at the time their petition
was filed. Petitioners have a son, Roderick Pinkney (Roderick),
who was approximately 41 years old during the year at issue. For
convenience, we combine our findings and discussion herein.
Unless otherwise indicated, all references to petitioner are to
Samuel Pinkney.
1 Respondent concedes deductions for $2,825 of charitable
cash contributions and $314.94 of other expenses. Petitioners
concede their gross income includes $1,063 of gambling winnings,
$14 of interest income from Fiscal Federal Credit Union, and $185
of gross receipts from Nuways, Inc. Petitioners also concede the
disallowance of deductions for $6,964.45 of medical and dental
expenses; $2,918 of charitable noncash contributions; $1,730 of
car and truck expenses; $4,149.72 of travel expense; $1,340.52 of
meals and entertainment expenses; and $2,135.16 of advertising
expense. Adjustments not addressed in this opinion are
computational.
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