Chrys L. Udoh - Page 5




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          Schedule C:  "Accessories And Apperals [sic]"                               
          Cost of goods sold                                $2,546                    
          Expenses:                                                                   
          Advertising                                  255                            
          Legal & professional services                     250                       
          Supplies                                          982                       
          Taxes & licenses                             216                            
          Travel                                       1,695                          
          Meals & entertainment                        397                            
          Other expenses:                                                             
          Transportation                          $967                                
          Telephone                               825                                 
          Freight charges & postage          483                                      
          Location rentals                                 396       2,671            
          Total                                             9,012                     
               Petitioner filed his 1994 return on May 3, 1996.  Petitioner           
          timely filed his 1995 return.  Upon examination of the returns,             
          respondent disallowed all of petitioner's claimed expenses2 and             
          cost of goods sold for 1994 due to lack of substantiation.                  
          Additionally, respondent adjusted petitioner's income for 1994 to           
          include $1,0983 received from United and $440 for the taxable               
          portion of petitioner's retirement distribution.  Respondent                
          asserted a 10-percent tax of $44 on the early distribution of               
          petitioner's retirement fund.  Respondent disallowed all but $452           

               2    Petitioner's expenses listed on the 1994 Schedule C,              
          "Clothing and Accessories", totaled $5,010.  We note the notice             
          of deficiency contains a typographical error with regard to the             
          disallowance of these expenses.  Although respondent disallowed             
          petitioner's expenses for 1994 in full, the notice of deficiency            
          lists the total amount of expenses disallowed as $5,001.                    
               3    The parties have stipulated $1,098 as the amount of               
          income petitioner received from United.  United issued petitioner           
          a Form 1099-MISC for 1994 reflecting income paid in the amount of           
          $1,098.39.  However, the notice of deficiency increased                     
          petitioner's income by the amount of $1,097.                                





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