- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008