Hi, please i need this homework to be solved by tomorrow May 8 before 2pm EST. Let me know if i need to pay an extra fee for it. thanks so much!

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Answered Same DayMay 07, 2023

Answer To: Hi, please i need this homework to be solved by tomorrow May 8 before 2pm EST. Let me know if i need...

Sandeep answered on May 08 2023
38 Votes
1.Statement of Problem:
he petitioner, a taxpayer, who was an attorney, was not entitled to take deductions under 26 U.S.C.S. § 162 for advertising expenses that he had
incurred in conducting racing car activities because these expenses were not ordinary and necessary expenses paid or incurred in carrying on his trade or business as an attorney, but rather, as contended by the respondent, the IRS, car racing was the petitioner's hobby; [2]-The petitioner was liable for the 26 U.S.C.S. § 6651(a)(1) late-filing addition to tax and for a failure to timely pay under § 6651(a)(2) because he offered no excuse for one late-filing of his tax return, and the fact that his tax returns were in the possession of his CPA did not excuse the other late-filings.
2.
According to section 6020(b) petitioner failed to file returns for 2008 & 2009 and IRS prepared SFRs. As per section 6081(a) petitioner secured extension of time to file his 2012 and return was timely filed on April 29, 2013. As per section 6651(a)(1) and (2), 6654 IRS sent petitioner notice of deficiency for 2008, 2009, and 2013 based on the SFRs and ascertained deficiencies of [*5] $3,752, $242,788, and $141,754, respectively, also over and above tax for failure to file and pay timely .Finally notice drafted as per section 6651(a)(1) finalized additions to tax and accuracy-related penalties as per section 6662(a).
3.
Respondents are of the same opinion that petitioner be allowed expense deduction claimed on delinquent and modified returns, except for Advertising expense.
According to section 6001, Roberts v. Commissioner, 62 T.C. 834, 836 (1974) taxpayers must prove that they met all requirements for deduction and maintained....
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