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Revenue Code in effect when 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 $4,888 deficiency in petitioner’s
2001 Federal income tax and a $977.60 accuracy-related penalty
pursuant to section 6662(a). After concessions,3 the issues for
decision are: (1) Whether petitioner is entitled to deductions
claimed on Schedule C, Profit or Loss From Business; (2) whether
petitioner correctly reported gross receipts on Schedule C; and
(3) whether petitioner is liable for the accuracy-related penalty
under section 6662(a).
Background
Some of the facts have been orally stipulated and are so
found. The stipulated facts and exhibits, as well as additional
exhibits introduced at trial, are incorporated herein by this
reference. Petitioner resided in Philadelphia, Pennsylvania,
when the petition was filed.
2 Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
3 Petitioner concedes in full the deductions she claimed on
Schedule A, Itemized Deductions. Respondent concedes that a
computational error of $828 was made in the notice of deficiency
to self-employment income.
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