Lindley Anthony Swanston - Page 6

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          shows several instances of numbers that are written over, which             
          suggests to the Court that petitioner altered the numbers to                
          attain a desired result.  In juggling the numbers, he apparently            
          forgot to correct the line totaling his expenses.  That line                
          showed total deductions of $18,223, when the correct amount was             
          $18,823.  That is not the only problem the Court has with the               
          return.  The return was a joint return, and one of the expenses             
          claimed on the Schedule C is wages of $550.  Petitioner testified           
          that this represented a payment to his wife for services she                
          rendered.  Yet, the return fails to reflect the $550 as gross               
          income that should have been reported because petitioner's wife             
          was reporting jointly with petitioner.  Some of the other                   
          expenses claimed on the Schedule C appear to be duplicative,                
          particularly expenses relating to a home office.  With respect to           
          the home office, the Schedule C claimed $755 for "office                    
          expenses", $1,200 for rent on business property (on petitioner's            
          home), and telephone and utilities of $4,230.  Aside from the               
          fact that all or some of these expenses appear to be duplicative,           
          petitioner presented no evidence that these expenses, if paid or            
          incurred, would be allowable under section 280A, which, in                  
          general, denies deductions with respect to the use of a dwelling            
          unit used by the taxpayer as a residence, unless such expenses              
          are, under section 280A(c)(1), allocable to that portion of the             







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