Wilburn C. Hall, Jr. - Page 27

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          for 1983, 1985, and 1986, respectively. Petitioner claimed                  
          deductions of $137,000 for "write-offs" on his tax return for               
          1982, $6,300 and $19,229 for bad debts on his tax returns for               
          1983 and 1984, respectively, and $36,451 for loan or investment             
          loss on his tax return for 1985. On other items listed on the               
          Schedules C of his tax returns, petitioner spent $58,874 for                
          1982; he claimed deductions of $18,872 for 1983, $14,137 for                
          1984, $14,799 for 1985, and $5,426 for 1986. Large portions of              
          these other items may fairly be described as office expenses.               
          _________________________________                                           
          Respondent exercised due care and diligence in ascertaining                 
          petitioner's correct mailing address before mailing the notice of           
          deficiency to petitioner on September 14, 1990. The notice of               
          deficiency was mailed to petitioner's last known address.                   
          Respondent's use of the Consumer Price Index method of                      
          royalty income reconstruction for 1983 was reasonable.                      
          The Corporations were corporations and remained corporations                
          throughout the years in issue. The expenses of the Corporations             
          are not expenses of petitioner's trade or business.                         
          Petitioner's office expenses that are deductible expenses of                
          his trade or business are in the following amounts: For 1982--              
          $27,000, for 1983--$8,000, for 1984--$5,000, for                            
          1985--$3,000, and for 1986 $1,000.                                          
          Petitioner was negligent in preparing his tax returns for                   
          1983 through 1986.                                                          




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