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$3,250 for 1987 and 1988, respectively. In addition, petitioner
embezzled $13,975 from her employer, Commander Construction,
during 1988. Subsequently, petitioner made payments in partial
restitution to Commander Construction in taxable years 1989,
1990, and 1991.
During the years at issue, petitioner claimed various
business expenses, rental expenses, and itemized deductions.
Petitioner attached a Schedule A to her 1987 Federal income tax
return. On Schedule A, petitioner claimed unsubstantiated
expenses in the amount of $3,460 as itemized deductions in 1987.
Petitioner also attached both Schedules C and E to her 1987
and 1988 Federal income tax returns. Petitioner operated United
Accounting & Management at her residence, 4401 Greenwood in
Beltsville, Maryland, during the years at issue. Petitioner
claimed the following amounts as business deductions on Schedule
C or rental property deductions on Schedule E:
Schedule on which the
Amount Year Amount was Claimed
$10,737 1988 Schedule C
1,927 1987 Schedule E
5,593 1988 Schedule E
All of these expenses were personal and, consequently, not
deductible.
Respondent concedes that petitioner is entitled to deduct
an additional $209 as a business deduction for 1987 and that
petitioner "overreported" her State income tax refund by the
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