-2-
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(f) 6651(a)(2) 6654
1999 $379,134 $274,850.40 $94,776.00 $18,346.93
2000 281,581 204,144.05 70,394.50 15,040.43
2001 452,670 328,185.75 113,167.50 18,090.37
2002 109,345 79,275.13 20,775.55 3,653.96
2003 70,143 50,853.68 9,118.59 1,835.66
All section references are to the Internal Revenue Code in effect
for the years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure. After concessions,1 the
issues remaining for decision are:
(1) Whether petitioner is entitled to any expense
deductions claimed on Schedule A, Itemized Deductions, or
Schedule C, Profit or Loss From Business, above those that
respondent concedes. We hold that he is not;
(2) whether petitioner may audit an organization that is
not a party to this case and pay the taxes he owes from the
proceeds of that audit. We hold that the Internal Revenue Code
(the Code) does not permit this offset against petitioner’s
income tax deficiency;
1 Petitioner concedes that he received income in the amounts
that respondent determined for the years in issue. Respondent
concedes that petitioner is entitled to some Schedule A itemized
deductions and Schedule C business expense deductions.
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Last modified: March 27, 2008