Sebold v. Commissioner

1988 T.C. Memo. 287, 55 T.C.M. 1196, 1988 Tax Ct. Memo LEXIS 314
CourtUnited States Tax Court
DecidedJune 29, 1988
DocketDocket No. 2250-85.
StatusUnpublished

This text of 1988 T.C. Memo. 287 (Sebold v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sebold v. Commissioner, 1988 T.C. Memo. 287, 55 T.C.M. 1196, 1988 Tax Ct. Memo LEXIS 314 (tax 1988).

Opinion

OTTO E. SEBOLD and JUTTA M. SEBOLD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sebold v. Commissioner
Docket No. 2250-85.
United States Tax Court
T.C. Memo 1988-287; 1988 Tax Ct. Memo LEXIS 314; 55 T.C.M. (CCH) 1196; T.C.M. (RIA) 88287;
June 29, 1988
Otto E. Sebold and Jutta M. Sebold, pro se.
Jane Wilson, for the respondent.

JACOBS

*316 MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge: Respondent determined a deficiency in Otto and Jutta Sebold's 1981 Federal income tax in the amount of $ 9,939 and additions to tax under sections 6651 (a) (1), 1 6653 (a) (1) and 6653 (a) (2) in the respective amounts 2 of $ 1,465, $ 497 and 50 percent of the interest due on the underpayment. At trial, it was revealed that Mr. Sebold signed his estranged wife's name to their purported joint income tax return for 1981, as well as to the petition filed in this case. 3 Mrs. Sebold did not authorize him to sign her name nor did she consent or intend to file a joint tax return or petition with her husband.

Based on the aforementioned revelation, we dismiss the case with respect to Mrs. Sebold, and respondent concedes that she is not liable for any of the deficiencies or additions to tax. By an amended answer to the petition, respondent*317 also seeks an increase in the deficiency and additions to tax against Mr. Sebold. As increased, the deficiency asserted against Mr. Sebold totals $ 14,849 and the additions to tax are $ 2,209 under section 6651 (a), $ 742 under section 6653 (a) (1) and 50 percent of the interest due on the increased underpayment under section 6653 (a) (2). 4

After concessions, the issues for consideration are: (1) whether Otto Sebold (hereinafter referred to as petitioner) is entitled to business expense deductions in excess of those allowed by respondent; (2) whether petitioner is entitled to use tax rates applicable to married individuals filing joint returns in computing his 1981 Federal income tax liability; (3) whether petitioner is liable for the addition to tax for failing to file a timely return; and (4) whether petitioner is liable for the additions to tax for negligence.

FINDINGS OF FACT

Petitioner resided in New York, New York at the*318 time he filed the petition herein.

During 1981, petitioner was employed as an engineer by Dermott Reddy, P.C.; he received wages in the amount of $ 39,006 from this employment. He also received $ 2,640 as a self-employed engineering consultant.

Petitioner filed a purported joint income tax return for 1981 with Mrs. Sebold on June 25, 1981; it was received by respondent's Holtsville, New York Service Center on June 28, 1982. He did not request an extension of time to file his 1981 tax return beyond the April 15, 1982 due date. 5 On Schedule C (Profit or Loss from Business or Profession) of the 1981 return, petitioner deducted the following expenses with respect to his consulting activity:

DeductionAmount
Bad DebtA $ 33,000
RentB 3,900
Checking Account48
Service Charge
Dues and PublicationsC   555
Storage and MovingD   283
Payments to five individualsE 9,071
TelephoneF 1,183
CleaningG   260
Office Supplies and PostageH   333
EntertainmentI 1,445
Total$ 50,078

*319

A Petitioner concedes this deduction.

B Petitioner used a room in an eight-room apartment which he shared with another tenant to conduct his consulting activity. He also lived in the room. Petitioner concedes $ 300 of this deduction.

C A portion of this expense represents the cost of having the New York Times delivered to petitioner's apartment.

D A substantial portion of this expense consists of the cost of moving a desk to an address that was not petitioner's business address.

E None of the five individuals were employees of petitioner. He contends that these payments were "advance commission payments." However, in correspondence with respondent, petitioner explained that payments to three of the individuals were for "financial support to friends without income."

F This includes payments made on a delinquent 1979 telephone bill as well as payments incurred in making long-distance calls to petitioner's relatives. Petitioner concedes $ 50 of this deduction.

G This represents petitioner's share of the cost of retaining a maid to clean the apartment which he leased. Petitioner concedes this deduction.

H Respondent concedes $ 30 of this deduction.

*320 I Petitioner concedes $ 500 of this deduction.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

French Republic v. Saratoga Vichy Spring Co.
191 U.S. 427 (Supreme Court, 1903)
Welch v. Helvering
290 U.S. 111 (Supreme Court, 1933)
Cohan v. Commissioner of Internal Revenue
39 F.2d 540 (Second Circuit, 1930)
Helfrich v. Commissioner
25 T.C. 404 (U.S. Tax Court, 1955)
Januschke v. Commissioner
48 T.C. 496 (U.S. Tax Court, 1967)
Thompson v. Commissioner
78 T.C. No. 38 (U.S. Tax Court, 1982)
Neely v. Commissioner
85 T.C. No. 56 (U.S. Tax Court, 1985)
Svedahl v. Commissioner
89 T.C. No. 21 (U.S. Tax Court, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
1988 T.C. Memo. 287, 55 T.C.M. 1196, 1988 Tax Ct. Memo LEXIS 314, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sebold-v-commissioner-tax-1988.