Samuel S. and Laura M. Pinkney - Page 3

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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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