Lucien Joseph Larvadain - Page 3

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         any other court, and this opinion shall not be treated as                    
         precedent for any other case.2                                               
              Respondent determined a deficiency of $7,106 in petitioner’s            
         2001 Federal income tax.  The sole issue for decision is whether             
         petitioner is entitled to deductions for certain expenses claimed            
         on Schedule C, Profit or Loss From Business, for the year at                 
         issue in excess of amounts allowed by respondent.  That issue is             
         premised on whether petitioner conducted a trade or business                 
         activity principally in his home.                                            
              Some of the facts were stipulated.  Those facts, with the               
         annexed exhibits, are so found and are made part hereof.                     
         Petitioner’s legal residence at the time the petition was filed              
         was Glen Burnie, Maryland.                                                   
              From 1974 to 1991, petitioner was an employee of the                    
         National Oceanic & Atmospheric Administration (NOAA), a Federal              
         agency.  Petitioner’s background is in naval navigation.  He left            
         his employment with NOAA in 1991 and commenced a self-employment             
         activity which dealt essentially in the sale of charts, maps,                
         nautical supplies, and navigational services to boat and yacht               
         owners.  Petitioner discontinued that activity around 1996 and               
         reestablished a relationship with NOAA as an independent                     

               2  Unless otherwise indicated, subsequent section references           
          are to the Internal Revenue Code in effect for the year at issue.           

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