Stephen J. Cotta, Sr. - Page 3




                                        - 2 -                                         
               Respondent determined a deficiency in petitioner’s Federal             
          income tax of $1,695 for the taxable year 1996.                             
               The issue for decision is whether petitioner is entitled to            
          deductions for business expenses and to the subtraction from                
          gross receipts for an amount of cost of goods sold.                         
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in San           
          Jose, California, on the date the petition was filed in this                
          case.                                                                       
               During 1996, petitioner earned $55,201 in wages from Applied           
          Materials, Inc. and Philips Semiconductors, Inc.  He also                   
          received $17,727 in pension and annuity income, primarily from              
          military retirement benefits.                                               
               Petitioner filed a Schedule C, Profit or Loss from Business,           
          with his 1996 Federal income tax return.  This schedule listed              
          petitioner as the proprietor of a housekeeping business named               
          “Beverly’s Housekeeping”.  The following amounts were reported on           
          the schedule:                                                               
                    Gross receipts                              $ -0-                 
                    Cost of goods sold                           (750)                
                    Expense deductions                                                
                    Advertising                  $6,000                               
                    Insurance                       775                               
                    Office expense                1,045                               
                    Supplies                        350                               
                    Meals and entertainment         437                               
                    Wages                           750                               
                    Total                                   (9,357)                   
                    Net loss                                  (10,107)                






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