- 2 -
at the time the petition was filed. Pursuant to section 7463(b),2
the decision to be entered is not reviewable by any other court,
and this opinion shall not be treated as precedent for any other
case.
Respondent determined a $6,463 deficiency in petitioner’s
2002 Federal income tax and a $123.10 addition to tax pursuant to
section 6651(a)(1). The issues for decision are: (1) Whether
petitioner conducted a trade or business as that term is used in
section 162; (2) if so, whether petitioner satisfied the
substantiation requirements for expenses relating to that trade or
business; and (3) whether petitioner is liable for the addition to
tax for failure to file a timely return under section 6651(a)(1).
Background
Some of the facts have been stipulated and are so found. The
stipulated facts and exhibits, as well as additional exhibits
introduced at trial, are incorporated herein by this reference.
At the time she filed the petition, petitioner resided in Herndon,
Virginia.
During 2002, the year at issue, petitioner was a part-time
employee of FedEx Express (FedEx), where she had worked since
1998. FedEx issued petitioner Form a W-2, Wage and Tax Statement,
for 2002 showing that she had earned wages of $42,355.39.
2Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: March 27, 2008