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this opinion shall not be treated as precedent for any other
case.
Respondent determined a $20,627 deficiency in petitioner’s
2001 Federal income tax, as well as a penalty of $4,125.40 under
section 6662(a). Respondent also determined a $16,293 deficiency
in petitioner’s 2002 Federal income tax, as well as a penalty of
$3,258.60 under section 6662(a). The issues for decision are:
(1) Whether the expenditures petitioner deducted on Schedule C,
Profit or Loss From Business, for 2001 and 2002 are subject to
the deductibility limitations of section 195; (2) whether
petitioner has substantiated those deductions; and (3) whether
petitioner is liable under section 6662(a) for accuracy-related
penalties for 2001 and 2002.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. At the time the petition was
filed, petitioner resided in Corvallis, Oregon.
During 2001 and 2002, petitioner was employed as the vice
president of strategy and business development by The Martin-
Brower Company, LLC. At the same time, petitioner and his wife
attempted to develop a business concept he called “Tasha’s
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