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(1) Whether the notice of deficiency is valid;
(2) whether petitioner was a statutory employee of
Technology Integration Group (TIG) for his 2000 taxable year;
(3) whether petitioner is entitled to a deduction of $5,253
for automobile expenses he incurred in 2000;
(4) whether petitioner is entitled to a deduction of $5,195
for loan interest that he allegedly paid to his mother in 2000;
(5) whether petitioner is entitled to a deduction of $1,750
for fees he allegedly paid to his mother for accounting, tax
preparation, and representation services performed in 2000;
(6) whether petitioner is entitled to $659 for cost of goods
sold in 2000;
(7) whether petitioner is entitled to a deduction for
$1,689.65 in legal fees and costs incurred in 2000.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Round Rock, Texas.
2(...continued)
00305 (S.D. Cal. filed Feb. 25, 1997), in the amount of
$5,911.65. Petitioner conceded that if it is ultimately
determined that the Tax Court has jurisdiction over the instant
case, then $10,157 that petitioner claimed as attorney fees for
Colvin v. Pennant Village Homeowners Association, No. 96-CV-01654
(S.D. Cal. filed Sept. 23, 1996), on Schedule A, Itemized
Deductions, as a miscellaneous expense is a nondeductible
personal expense.
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