St. Elmo H. Nauman, Jr. - Page 5

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          general information and allegedly were used for lecturing                   
          purposes.                                                                   
               Petitioner worked about 40 hours per week for the INS, 10              
          hours per week teaching at Chapman, 5 hours per week on other               
          lecturing activity, and an undeterminable amount of time on his             
          real estate project.  Petitioner wrote during his remaining free            
          time.  Other than the spiral calendar and small notebook                    
          previously mentioned, petitioner did not maintain books or                  
          records for any of his activities.                                          
               On his Schedule C for 1993, petitioner listed his principal            
          business or profession as “Religion” and reported no income from            
          that activity, but claimed the following expenses:                          

                         Expenses                Amount                               
                         Car & truck         $4,695                                   
                         Depreciation             9,320                               
                         Office                   851                                 
                         Travel              266                                      
                         Meals                   88                                   
          Total                              15,220                                   
          Petitioner’s car and truck expense deduction is based on the                
          mileage driven for commuting from home to the various places                
          listed in the log.  Petitioner’s depreciation deduction is for              
          “Professional books and equipment”, of which $8,000 relates to              
          depreciation on 6,400 books with a purported $160,000 purchase              
          price and $1,320 relates to depreciation on various office                  
          equipment, such as desks, bookcases, filing cabinets, furniture,            





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