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taxable year 2001 to deduct under section 162(a)1 the $5,066
claimed for “Employee benefit programs” in Schedule C, Profit or
Loss From Business (petitioners’ 2001 Schedule C), included as
part of their tax return for that year. We hold that they are
not.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted
under Rule 122, have been stipulated by the parties and are so
found.
Petitioners resided in Gibson, Iowa, at the time they filed
the petition in this case.
At all relevant times, petitioner Geoff Eyler (Mr. Eyler)
owned and operated a tiling business that involved his using
certain specialized machinery for controlling water flow and for
draining water.
During 2001, the year at issue, Mr. Eyler had one full-time
employee in his tiling business, viz., his spouse petitioner
Audrey Eyler (Ms. Eyler), who had been an employee of Mr. Eyler’s
tiling business since December 1997. During 2001, Ms. Eyler
performed certain services for that business,2 for which Mr.
1All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
2The record does not disclose the type of services that Ms.
Eyler provided during 2001 for Mr. Eyler’s tiling business.
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