- 3 - (2) whether petitioners had cost of goods sold of $18,367.57 for taxable year 2000; (3) whether petitioners are entitled to expense $6,902.80 in depreciable business assets purchased in taxable year 2000; (4) whether petitioners are entitled to claim Schedule C deductions in excess of the $5,193.10 and $14,936, for 2000 and 2001, respectively, that respondent has previously allowed or conceded;4 (5) whether petitioners are liable for the section 6662 accuracy-related penalty for taxable year 2000; (6) whether to grant petitioners’ motion to impose sanctions on respondent pursuant to Rule 104(c). FINDINGS OF FACT Some of the facts have been stipulated by the parties. The stipulations, with accompanying exhibits, are incorporated herein by this reference. At the time the petition was filed petitioners resided in Austin, Texas. 3(...continued) amount of petitioners’ startup expenditures is moot as the Court concludes, infra, that petitioners are not entitled to deduct their startup expenditures. The Court notes that petitioners claimed $45,496.27 in Schedule C deductions for 2000 and were unable to substantiate most of those deductions. 4The Court notes that in calculating their 2001 Schedule C expenses petitioners made an error that respondent did not notice. See infra note 12. The $14,936 amount is based on the Court’s calculation, correcting for the error, of the Schedule C expenses allowed or conceded by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008