John Joseph Stensgaard - Page 6




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               Petitioner prepared a computer-generated spreadsheet listing           
          19 categories of business expenses.  Petitioner provided at trial           
          copies of 18 checks written between January and April 2003,                 
          miscellaneous credit card records, bank statements, and receipts            
          as substantiation for Schedule C expenses.  After reviewing                 
          petitioner’s evidence, respondent conceded that he has                      
          substantiated $8,106 of business expenses in 2003:  Advertising             
          expense of $575, commissions and fees of $75, office expense of             
          $2,613, supplies expense of $1,221, taxes and license fees of               
          $325, utilities expense of $2,306, and $991 for legal and                   
          professional services.                                                      
               Petitioner offered no substantiation for his business                  
          expense categories denominated as donations, “mortgage”, and                
          consulting.  Petitioner offered two monthly receipts for                    
          telephone expenses that state that they are for his residential             
          line, a type of personal expense.  Sec. 262(b).                             
               Other categories of expenses listed on petitioner’s spread             
          sheet included those of “Vehicle”, “Ins.”, Travel, “Tr. Meals”,             
          Meals, and “Entert.”  Petitioner’s evidence included billing                
          statements reflecting lease payments to Ford Credit for a truck             
          and payments for automobile insurance to Safeco Insurance Co.  He           
          also produced a receipt for a hotel stay at the Sahara Hotel and            
          Casino in Las Vegas and a computer printout of an Orbitz                    
          reservation for a trip to Houston.                                          







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