- 2 - 2001 and 2002; (3) petitioners failed to report gross income relating to 2001 and 2002; and (4) petitioners are liable for section 6662(a)1 accuracy-related penalties. FINDINGS OF FACT Petitioner Donald Osborne (Mr. Osborne) was a self-employed truck driver. In addition, he maintained a business, Don Osborne Enterprises, which rented trailers and bought and sold over-the- road trucks and trailers. On his Schedules C, Profit or Loss from Business, relating to 2001 and 2002, Mr. Osborne combined income and expenses relating to these activities and claimed expense deductions for depreciation, insurance, interest, supplies, tax and licenses, travel, and other expenses. In 2004, petitioners’ 2001 and 2002 returns were selected for audit, and respondent’s Revenue Agent Mary Miller began an examination of the items on the returns. To substantiate their expense deductions, petitioners submitted canceled checks, credit card statements, insurance records, and other documentation. Petitioners were given credit for the expenses that were properly substantiated. Using canceled checks and vehicle title information for Mr. Osborne’s business, Ms. Miller made adjustments to the inventory, cost of goods sold, and depreciable 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 NextLast modified: March 27, 2008