- 2 - The decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority. Respondent determined the following deficiencies in Federal income taxes and the penalties for fraud under section 6663(a): Penalty Year Deficiency Sec. 6663(a) 1994 $3,360 $2,520 1995 2,623 1,967 The issues for decision are: (1) Whether petitioners are entitled to deduct on Schedules C, Profit or Loss From Business, losses in the amounts of $19,738.50 and $17,125.39, respectively, for 1994 and 1995, and (2) whether petitioner wife Penny Rhodes (Ms. Rhodes) is liable for section 6663(a) penalties for fraud with respect to the joint 1994 and 1995 Federal income tax returns of her and her spouse. Some of the facts were stipulated. Those facts, with the annexed exhibits, are so found and are incorporated herein by reference. Petitioners’ legal residence at the time the petition was filed was Garrett, Indiana. During the years at issue, petitioners lived and worked in Garrett, Indiana. Petitioner husband (Mr. Rhodes) was a railroad brakeman and conductor for CSX Transportation, Inc., during the years at issue. Beginning in 1993 and during the years at issue, Ms. Rhodes operated Keepsake Designer Creations (Keepsake), aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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