- 2 - The issues remaining for decision2 are: (1) Is petitioner entitled to deduct certain claimed amounts as unreimbursed employee expenses? We hold that he is not. (2) Is petitioner entitled to a claimed Schedule C net loss with respect to a claimed restaurant business? We hold that he is not. (3) Is petitioner entitled to a claimed Schedule C net loss with respect to a claimed personal digital assistant consulting business? We hold that he is not. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time petitioner filed the petition in this case, he resided in Dallas, Texas. During 2001, FedEx Worldwide Services, one of the FedEx companies, employed petitioner full time as a worldwide account manager. Pursuant to certain policies (FedEx policies),3 FedEx Worldwide Services agreed to reimburse employees for reasonable 2On brief, petitioner lists as an issue: “Allowance of ordinary losses from the sale of vehicles used in a trade or business or held as income producing property.” However, peti- tioner states on brief: “With regard to the loss on the sale of the vehicles, although petitioner believes that a minimal loss should be allowed, he will not challenge the findings of the respondent on that specific issue.” We conclude that petitioner has abandoned the issue of whether he is entitled to deduct as losses under sec. 1231(a)(2) certain claimed losses from the sale of certain vehicles. 3The FedEx policies applied to FedEx Worldwide Services and at least one other FedEx company (viz., FedEx Express).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011