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other court, and this opinion shall not be cited as precedent for
any other case.
Respondent determined a $15,841 deficiency in petitioner’s
2002 Federal income tax. The issue for decision is whether
petitioner is entitled to certain deductions claimed on a
Schedule C, Profit or Loss From Business, included with his 2002
Federal income tax return.
Background
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
California.
During the year in issue petitioner sold securities and/or
financial products as an independent contractor for National
Planning Corp. (NPC). His compensation for doing so was paid in
the form of commissions that were directly deposited into one or
another of two “regular personal” checking accounts maintained at
China Trust, U.S.A. (Trust). One of those accounts was
petitioner’s individual account; the other was a joint account
that petitioner maintained with three business associates.
Petitioner and those three business associates each owned
25 percent of the stock of Wise Steward Corp. (Wise), a
California corporation that offered financial planning services
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