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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: This case is before the Court on a petition
for redetermination of Federal income tax deficiencies and
additions to tax under section 6651(a)(1) that respondent
determined with respect to petitioner’s 1999, 2000, 2001, and
2002 taxable years.1
Before trial, the parties resolved a number of issues and
filed a stipulation of settled issues, which is hereby
incorporated by reference into our findings. After concessions,
the issues remaining for decision are:
(1) Whether petitioner is entitled to numerous additional
deductions claimed on Schedule C, Profit or Loss From Business,
for all 4 taxable years at issue;
(2) whether petitioner is entitled to a deduction for state
taxes paid in 2000; and
(3) whether petitioner is entitled to a deduction for
alimony payments in 2001.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts and accompanying exhibits are hereby incorporated by
reference into our findings. Petitioner failed to file Federal
1 All section references are to the Internal Revenue Code of
1986, as amended and in effect for the taxable years at issue.
The Rule reference is to the Tax Court Rules of Practice and
Procedure.
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Last modified: March 27, 2008