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entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a deficiency of $1,760 in petitioner’s
2000 Federal income tax and a $352 accuracy-related penalty under
section 6662(a).
The issues for decision are: (1) Whether petitioner is
entitled to various deductions claimed on Schedule A, Itemized
Deductions; and (2) whether the underpayment of tax required to
be shown on petitioner’s 2000 Federal income tax return is due to
negligence or intentional disregard of rules or regulations.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in New York,
New York.
Petitioner holds a bachelor’s degree from the University of
Idaho. In 1993 he began employment with Cooper Union School of
Engineering (Cooper Union) as a technician in the chemistry
department. While employed by Cooper Union, petitioner enrolled
in its graduate program and in 1998, he was awarded a master’s
degree in engineering.
While working and attending classes at Cooper Union,
petitioner incorporated Suffola, Inc. (Suffola), a corporation
organized under the laws of Idaho. At all relevant times,
petitioner was the sole owner of all of Suffola’s outstanding
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