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1988 1989 1990
Per return $4,558 $14,729 $7,028
Per exam 4,034 3,346 3,3317
Adjustment 524 11,3818 3,697
Petitioner offered no testimony or other evidence to
identify, describe, or justify the $524 amount disallowed for
1988. Consequently, respondent's disallowance is sustained.
Unlike 1988 and 1990, petitioner produced some books and
records for 1989. The 1989 supplies adjustment is complicated.
Petitioner had two 1989 accounts, called "office expenses" and
"books and reference materials", respectively. According to his
records, his "office expenses" amounted to $20,838 and his "books
and reference materials" cost $3,889, a total of $24,729.
Petitioner deducted $10,000 of the $24,729 under depreciation as
a section 179 expense and deducted the rest, $14,729, on the
"supplies" line of Schedule C of the 1989 return.
Respondent evaluated petitioner's "office expenses" and
"books and reference materials" separately, and disallowed $7,703
of petitioner's office expenses for 1989, $6,744 of which
petitioner conceded on brief. The conceded amount includes a
computer that cost $6,056 and which was returned on the day it
was purchased, but which petitioner nevertheless claimed as a
7 $3,331 is the amount respondent determined. The parties, however,
mistakenly stipulated $3,697, which we simply disregard.
8 There is a $2 subtraction error in petitioner's favor, which we
accept.
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