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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Last modified: March 27, 2008