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Respondent determined a deficiency of $2,214 and an
accuracy-related penalty under section 6662(a) of $442.80 in
petitioner’s 2002 Federal income tax. At the time the petition
was filed, petitioner resided in Covington, Georgia.
The relevant facts may be summarized as follows. During
2002, petitioner was employed full-time at an airport in Atlanta,
Georgia. For approximately 15 years, petitioner owned a so-
called “dirt” motorcycle or bike. In 2001, he sold the dirt bike
and on May 15, 2002, purchased a so-called “street” motorcycle or
bike for $9,490. On May 6, 2002, prior to purchasing the street
bike, petitioner completed an Introduction to Motorcycle Riding
course provided at the Atlanta Motorcycle Schools.
Petitioner alleges that in 2002 he was engaged in the
business of providing motorcycle lessons to other parties.
Petitioner allegedly operated the business, Safe Cycle, as a sole
proprietorship. On Schedule C, Profit or Loss From Business, of
his 2002 return petitioner reported income of $425 received from
two alleged clients and claimed deductions totaling $8,621 as
follows:
Car & truck expenses $1,721
Advertising 50
Depreciation 5,472
Office expense 75
Supplies 104
Other expenses 1,199
The “other expenses” include $550 for Internet service. However,
Safe Cycle did not have a Web page. Petitioner did not obtain a
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