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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies of $4,945 and $4,734,
respectively, in petitioner’s 2001 and 2002 Federal income tax.1
Respondent also determined an accuracy-related penalty for each
year. The issues for decision are (1) whether petitioner can
deduct business-related expenses, and (2) whether petitioner is
liable for the accuracy-related penalties.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time the petition was filed,
petitioner resided in Pittsburg, California.
In 2001 and 2002, petitioner was employed full-time by the
Internal Revenue Service as an examination group manager.
Petitioner also operated a cleaning business on weekends and
holidays.
During the years at issue, petitioner owned a Plymouth
Voyager (the Voyager). In July 2001, petitioner also purchased a
Chevrolet Astro Van (the Astro Van) for a total of $25,379 after
1 All dollar amounts are rounded to the nearest dollar.
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Last modified: November 10, 2007