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the year in issue, and Rule references are to the Tax Court Rules
of Practice and Procedure.
Initially, 2 tax years were involved herein. Docket No.
9978-05S pertains to 2002. Docket No. 4802-06S pertains to 2003.
Before the trial of these cases, respondent conceded all issues
for 2003. Consequently, only the dispute for 2002 remains for
decision, and the issues to be resolved for that year are: (1)
Whether petitioner Robert H. Goode’s activity reported on Schedule
C, Profit or Loss from Business--a construction activity known
during 2002 as Robco Construction and Service Co. (Robco)--was an
activity engaged in for profit; and, if so, (2) whether
petitioners have satisfied the substantiation requirements for
claimed Schedule C expenses related to (a) the business use of a
pickup truck and stretch van and (b) power tools.
Background
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. At the time they filed the petitions,
petitioners resided in Spring, Texas.
Petitioner Robert H. Goode (Mr. Goode) is a 1962 graduate of
the U.S. Military Academy at West Point, where he received degrees
in engineering. Mr. Goode served as an artillery officer in Korea
and Vietnam and received numerous commendations, including three
Purple Hearts, the Distinguished Flying Cross, the Distinguished
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