Joshua A. Van Ryswyk, (2009)

United States Tax Court

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Joshua A. Van Ryswyk, (2009)

T.C. Memo. 2009-189

UNITED STATES TAX COURT JOSHUA A. VAN RYSWYK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5607-08. Filed August 19, 2009.

James R. Monroe, for petitioner. Michael W. Bitner, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: Respondent determined the following deficiency in, and additions to, petitioner's Federal income tax (tax) for his taxable year 2004:

Deficiency Additions to Tax Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a) $16,776 $3,774.60 $2,768.04 $486.97

The issues remaining for decision for petitioner's taxable year 2004 are: (1) Are certain commissions that petitioner received during 2004 includible as nonemployee compensation in his gross income? We hold that they are. (2) Is petitioner entitled to deduct under section 162(a) certain amounts that he claims he paid to Baccam & Associates (B&A) during 2004? We hold that he is not. (3) Is petitioner entitled to deduct under section 162(a) certain claimed expenses that B&A showed as deductions in the tax return that it filed for taxable year 2004? We hold that he is not. (4) Is petitioner liable for the addition to tax ...

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