Jack C. Goins, Sr. and Edith M. Goins - Page 11




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          in issue.  See sec. 274(d).  Consequently, petitioner is not                
          entitled to any of the traveling expense deductions claimed on              
          the Schedules C.  Respondent’s determinations in this regard are            
          therefore sustained.                                                        
               Other types of business expenses were deducted on the                  
          Schedules C and disallowed by respondent.  Petitioner was not               
          entitled to reimbursement for these expenses.  We find that, for            
          the year 1993, petitioner is entitled to deductions for these               
          expenses as follows:                                                        
                         Type of Expense          Amount                              
                         Supplies                 $1,431                              
                         Depreciation             500                                 
                         Postage                  10                                  
                         Taxes                    60                                  
                         Telephone                265                                 
                        Total                    2,266                               
          Because the record does not contain adequate substantiating                 
          evidence of business expenses that petitioner may have incurred             
          in 1994, or any evidence from which we can reasonably estimate              
          such expenses, petitioners are not entitled to any business                 
          expense deductions for the year 1994.                                       
               Petitioner maintains that he provided services to the DOI              
          during the years in issue as an independent contractor.   All of            
          the deductions here in dispute were claimed on a Schedule C as              
          though petitioner were not an employee of the DOI during either             
          year in issue.                                                              







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