- 27 - 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.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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