Glenn Bogue v. Commissioner of Internal Reven

OPINION

Glenn Patrick Bogue appeals from a decision of the United States Tax Court, which determined that there were deficiencies in income tax due from Bogue in the amount of $4,680.80 for taxable year 2005, and $4,961.85 for taxable year 2006, due to its disallowance of certain of Bogue’s business deductions. For the reasons that follow, we will affirm the Tax Court’s decision.

We have jurisdiction pursuant to 26 U.S.C. § 7482(a)(1). We review the Tax Court’s factual findings for clear error and its legal conclusions de novo. See PNC Bancorp, Inc. v. Comm’r, 212 F.3d 822, 827 (3d Cir.2000).…