Benjamin O. & Linda L. Agbaniyaka - Page 2




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          Accuracy-Related Penalty                                                    
          Year           Deficiency           Under Sec. 6662(a)                      
          2001             $3,301                      $660.20                        
          2002             $3,727                  $745.40                            
          2003             $2,137                  $427.40                            
          2004             $1,600                  $320.00                            
               The issues remaining for decision are:                                 
               (1) Are petitioners entitled to deduct for each of their               
          taxable years 2002 through 2004 certain claimed unreimbursed                
          employee expenses?  We hold that they are not.                              
               (2) Are petitioners entitled for each of their taxable years           
          2001 through 2004 to a net loss shown in Schedule C, Profit or              
          Loss From Business, with respect to a claimed arts and crafts               
          business?  We hold that they are not.                                       
               (3) Are petitioners entitled to deduct for their taxable               
          year 2003 certain claimed student loan interest?  We hold that              
          they are not.                                                               
               (4) Are petitioners liable for each of their taxable years             
          2001 through 2004 for the accuracy-related penalty under section            
          6662(a)?  We hold that they are.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time petitioners filed the petition in this case,               
          they resided in Valley Stream, New York.                                    
               During the years at issue, petitioner Benjamin O. Agbaniyaka           
          (Mr. Agbaniyaka), who holds a master’s degree in accounting with            






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