- 2 -
the years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Respondent determined deficiencies of $5,995, $5,060, and
$6,089 in petitioner’s Federal income taxes, and accuracy-related
penalties under section 6662(a) of $1,199, $1,012, and $1,217.80
for taxable years 2000, 2001, and 2002, respectively. The issues
for decision are: (1) Whether, for the taxable years in issue,
an activity conducted by petitioner known as Royster Basketball
School constituted an activity engaged in for profit within the
meaning of section 183(a); (2) whether petitioner is entitled to
deduct expenses relating to Royster Basketball School during the
years in issue under either the foregoing section or, in the
alternative, section 183(b)(1) and (2); and (3) whether
petitioner is liable for the accuracy-related penalty under
section 6662(a) for negligence or disregard of the rules or
regulations for each of the years at issue.1
1 Two adjustments in the notice of deficiency were not
addressed at trial and are, therefore, deemed conceded. One of
these adjustments relates to whether petitioner is liable for
self-employment tax stemming from his work as a basketball
referee during the years at issue, and as listed on the Schedules
C, Profit or Loss From Business, he attached to his returns for
2000, 2001, and 2002. Respondent determined that petitioner is
liable for self-employment tax on that income with a
corresponding deduction for one-half of that tax. The second
adjustment that is also deemed conceded relates to unreported
income in the amount of $875 received in 2000.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007