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the Internal Revenue Code for the year in issue and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s 2001
Federal income tax of $7,514 and additions to tax under section
6651(a)(1) of $1,691, under section 6651(a)(2) of $1,578, and
under section 6654 of $297.
After concessions,1 the issues for decision are: (1)
Whether petitioner is entitled to business expense deductions for
2001 and (2) whether petitioner is liable for additions to tax
for failing to file a 2001 tax return, for failing to pay the
amount shown as due on a tax return, and for failing to pay
estimated taxes.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts, with accompanying exhibits, is
incorporated herein by this reference.
At the time he filed the petition, petitioner resided in
Apopka, Florida. Petitioner has installed ceramic tile since
1957, and he operated a tile business in 2001. Petitioner
accepted checks in payment for work performed and cashed those
1 At trial, respondent conceded that petitioner is entitled
to a filing status of married filing jointly and to a deduction
for home mortgage interest paid in 2001.
By stipulation, petitioner conceded that for 2001 he
received $7,224 of Social Security income and $27,066 of
nonemployee compensation, and did not file a 2001 tax return.
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