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reviewable by any other court, and this opinion shall not be
treated as precedent for any other case. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code (Code) in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency of $1,436 in petitioner’s
2002 Federal income tax and an accuracy-related penalty under
section 6662 of $287.20.
The issues for decision are: (1) Whether petitioner is
entitled to deduct the expenses of her master of business
administration (M.B.A.) program at Harvard Business School (HBS);
and (2) whether petitioner is liable for the section 6662 penalty
for negligence or disregard of rules or regulations.
Background
The parties stipulated some of the facts, and they are so
found. We incorporate the stipulation of facts and the attached
exhibits herein by this reference. Petitioner resided in
California when she filed the petition in this case.2
2 The Court conducted the trial of this case in Boston,
Mass., as petitioner requested. Petitioner did not attend the
trial. Presumably, she still lived in California at the time of
trial. As will be discussed infra, petitioner did not provide
any testimony at trial. The record is thus limited to the
stipulation of facts with attached exhibits, matters deemed
admitted, Rule 90(c), and additional exhibits admitted in
evidence at trial.
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