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The issues to be decided are: (1) Whether petitioner is
entitled to business deductions incurred in connection with his
software development activities in 2003; and (2) whether
petitioner is liable for the accuracy-related penalty under
section 6662.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in New
York, New York, at the time the petition was filed.
During 2003, petitioner was employed by various companies as
a computer programmer and/or consultant. In addition, in
September 2003 petitioner purportedly initiated the development
of a computer software business in which he was the sole
proprietor. In this capacity, he was interested in developing
software for use by financial companies.
Petitioner timely filed his Form 1040, U.S. Individual
Income Tax Return, for 2003. Petitioner’s Schedule C, Profit or
Loss From Business, for 2003 reported that his computer software
business had gross receipts of $17,149, incurred a car and truck
expense of $3,977, incurred a labor expense of $7,070, and
1(...continued)
are rounded to the nearest dollar.
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