KARKOUR v. COMMISSIONER OF INTERNAL REVENUE Leagle.com
(7) whether petitioner is liable for a section 6662(a) accuracy-related penalty for the 2005 tax year.
FINDINGS OF FACTSome of the facts have been stipulated, and the stipulated facts and the accompanying exhibits are hereby incorporated by reference into our findings. At the time he filed his petition, petitioner resided in California.
In 2005 petitioner was self-employed as a lien collector; his title was lien representative. He claimed $1,900 and $2,300 deductions for SEP and self-employment health insurance, respectively. He deducted $51,709 in business expenses on Schedule C for 2005. Petitioner included deductions on Schedule A for medical expenses, home interest expenses, and unreimbursed employee expenses. Petitioner filed a Schedule SE, Self-Employment Tax, which included zero net earnings from self-employment and subsequently listed zero self-employment tax owed.
Respondent issued a notice of deficiency on April 17, 2008, determining an alleged income tax deficiency of $7,164 and an accuracy-related penalty of $1,432.80. Petitioner filed a timely petition with this Court on July 2, 2008, denying liability for the deficiency. A trial was held on June 19, 2009, in Los Angeles, California.
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