Craig E. and Debbie A. Brown - Page 5

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               Petitioner and Mr. Glass made one demonstration of the                 
          record-keeping software to a woman who was the owner of a small             
          business; however, the date of this demonstration is unknown. No            
          records of the joint venture were produced, no testimony was                
          elicited as to an amount of any specific expenditure, and Mr.               
          Glass indicated that petitioner did not contribute any funds to             
          the joint venture. Petitioners filed their 1989 Federal income              
          tax return (the original return) on or before April 15, 1990. The           
          original return was prepared by the accounting firm of Williams &           
          Tucker. On the Schedule C attached to the return, petitioner                
          reported gross income from his computer consulting activity in              
          the amount of $81,817 and claimed the following expenses:                   
                    Expense        Amount claimed                                     
               Car and truck            $3,390                                        
               Rent/lease of                                                          
               business equipment           50                                        
               Supplies                    138                                        
               Travel                    1,562                                        
               Meals and entertainment     140                                        
               Utilities                   432                                        
               Education                 1,824                                        
               Bank charges                153                                        
               Laundry                     520                                        
               Temporary help            2,525                                        
               Home office               1,253                                        
                                        11,987                                        
          On that return, petitioners claimed a charitable contribution               
          deduction in the amount of $18,151 on Schedule A and a child care           
          credit in the amount of $960.                                               








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