Sharon T. Myrick - Page 3




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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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