PURSUANT TO INTERNAL REVENUE CODE
SECTION 7463(b),THIS OPINION MAY NOT
BE TREATED AS PRECEDENT FOR ANY
T.C. Summary Opinion 2006-60
UNITED STATES TAX COURT
EMMANUEL AND CECILIA ABLOSO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 898-04S. Filed April 19, 2006.
Emmanuel and Cecilia Abloso, pro se.
Guy Glaser, Kim-Khanh Thi Nguyen, and Sherri S. Wilder,
CARLUZZO, Special Trial Judge: This case for the
redetermination of a deficiency was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
at the time the petition was filed. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
effect for 2000. Rule references are to the Tax Court Rules of
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Practice and Procedure. The decision to be entered is not
reviewable by any other court, and this opinion should not be
cited as authority.
Respondent determined a deficiency of $3,177 in petitioners’
2000 Federal income tax and imposed a $635.40 section 6662(a)
accuracy-related penalty. The issues for decision are: (1)
Whether petitioners are entitled to various deductions claimed on
a Schedule C, Profit or Loss From Business, included with their
2000 joint Federal income tax return; and (2) whether the
underpayment of tax required to be shown on petitioners’ 2000
return is due to negligence or intentional disregard of rules or
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioners resided in Fontana,
California. References to petitioner are to Emmanuel Abloso.
For most of the year in issue, petitioner was employed full
time by ANVICOM. Petitioner worked “at least 40 hours a week”
there and earned wages of $43,741.
In 1999, petitioner attended a seminar conducted by
Renaissance TTP, Inc. (Renaissance). Renaissance sometimes
refers to itself in its publications as “The Tax