- 2 - whether petitioner is entitled to certain deductions and is liable for the section 6662(a) accuracy-related penalty relating to 1998. Background During 1998, petitioner and his brother, Patrick Grabowski, operated several businesses including a property management company, a trailer park, and two motels (collectively, the businesses). Petitioner was responsible for the onsite management of the businesses while Patrick paid the expenses and maintained the books and records. Petitioner, on his 1998 Federal income tax return, reported losses relating to the businesses. On April 25, 2005, respondent issued petitioner a notice of deficiency relating to 1998. Respondent determined that petitioner did not substantiate the losses relating to the businesses and was liable for the section 6662(a) accuracy-related penalty. On July 25, 2005, petitioner, while residing in Lake Ozark, Missouri, filed his petition with the Court. Discussion Petitioner contends that the losses relating to the motels and trailer park are deductible pursuant to section 162. Section 162(a) allows as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on a trade or business. Petitioner must maintain sufficient recordsPage: Previous 1 2 3 4 5 NextLast modified: November 10, 2007