- 3 -
Petitioner received a B.A. degree in history from California
State University at Sacramento. He has written five unpublished
novels, including: Great Woods Poppy; Trappers; Forever Three
Friday; Positively People; and Atla One, the first of a trilogy.
With respect to his activities as a "self-employed
writer/editor/educator", petitioner reported income and claimed
expenses on Schedules C as follows:3
Expenses 1990 1991 1992
Car and truck expenses $4,187 $5,633 $10,228
Insurance 2,549 2,917 2,597
Legal and professional services 139 100 545
Office expense 157 1,498 1,647
Vehicle lease 2,621 2,639 2,658
Lease of other business property 3,222 2,925 3,130
Repairs and maintenance 48 582 629
Taxes and licenses 445 535 527
Travel, meals, and entertainment 1,892 738 1,833
Utilities 1,393 2,263 1,702
Postage 75 151 211
Research 9,455 10,237 4,366
Writing experimentation 67 255 171
Telephone 784 910 804
Total expenses 27,034 31,383 31,048
Gross income 2,356 11,421 3,419
Net income/loss (24,678) (29,962) (27,629)
1 Petitioner now concedes that this amount
constituted gambling income, unrelated to his writing
activities. See supra note 2.
3 The items and amounts listed are taken from petitioner's
amended returns (Forms 1040X) for the years 1990, 1991, and 1992.
On the amended returns, petitioner claimed larger deductions than
claimed on his original returns. The notice of deficiency
specifically disallows the amounts claimed on both the original
and the amended returns.
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