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Rallye Motors, he incurred expenses incident to that employment
for which he did not feel it was proper to claim reimbursement.
Petitioner has provided no detail of any expenses he may have
incurred. Petitioner has failed to convince us that, during
1988, he incurred any unreimbursed, business-related expenses.
Petitioner has failed to carry his burden of proof on this issue,
and we sustain so much of respondent’s determination as relates
thereto.
3. Schedule C Deductions
In her notice of deficiency, respondent included adjustments
disallowing “Schedule C Expenses” for 1987 and 1988 in the
amounts of $5,331 and $4,745, respectively. After taking into
account concessions by the parties, only the following expenses
remain in dispute:
1987 1988
Car & truck $687 $815
Dues 185 122
Office, rent & utilities 1,651 1,691
Supplies 68 263
Those expenses were claimed by petitioner on Schedules C, Profit
or Loss From Business, attached to petitioner’s Forms 1040 for
1987 and 1988, respectively. Those Schedules C identify the
trade or business in question as horse racing and breeding.
Respondent has allowed substantial amounts as deductions in
connection with petitioner’s horse racing and breeding business.
Petitioner has not convinced us that he incurred deductible
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