-7- attached to the return, one listing petitioner as the proprietor of Glass Onion Records ("Businesswoman, Retail Sales, Marketing"), and the other listing Mr. Edmondson as proprietor of S.M.E. Contracting Co.4 ("General Contractor"). On the Schedule C relating to Glass Onion Records, $18,188.01 of expenses was claimed; among other things, the expenses were with respect to: Debts of Glass Onion Records prior to its failure; a 1988 trip to Mexico; and petitioner's education. On the Schedule C relating to S.M.E. Contracting Co., $19,406.13 of expenses was claimed; among other things, the expenses were with respect to renovations to the Floyd Avenue house. Attached to the Edmondsons' 1988 return was a Form 2119 (Sale of Principal Residence), wherein $30,948.64 of gain from the sale of Mr. Edmondson's Seattle house was deferred. Notice of Deficiency and Amended Answer Respondent disallowed all deductions claimed on the two Schedules C on the basis that the Edmondsons failed to establish that the expenses were deductible under section 162(a). In the amended answer, respondent asserted that the deferral of the $30,948.64 gain from the sale of Mr. Edmondson's Seattle house was erroneous. 4 Except for the 1988 tax return, there is no evidence in the record with regard to S.M.E. Contracting Co.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011