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accounting/computer consulting business. On Schedule C of his
1991 return, petitioner reported income totaling $7,195 and
expenses totaling $5,560. The expenses listed on petitioner's
Schedule C are as follows:
Car and truck expenses $1,950
Depreciation and section 179 expenses1 1,945
Other 425
Supplies 945
Subscriptions 295
Total expenses $5,560
1 The sec. 179 expenses petitioner reported were computer
expenses.
The parties stipulated that petitioner received $7,195 in
gross receipts from his Schedule C business. The stipulation
also reflects that petitioner submitted the following receipts as
substantiation for the claimed Schedule C expenses:
Automotive expenses:
Gary's Automotive $848.88
Computer expenses:
Sam's Club 1,368.85
Software Gallery 234.32
Other:
Clerk of Superior Court 80.00
Total expenses $2,532.05
Respondent disallowed the claimed expenses on the basis that
petitioner failed to establish that they were ordinary and
necessary business expenses, and, further, that some of the
claimed expenses were not substantiated (including satisfying the
provisions of section 274(d)). Petitioner argues that he is
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