Keith F. Marason - Page 17

                                        - 17 -                                        
               For the above reasons, we agree with respondent's                      
          determination regarding the remaining 1989 and 1990 travel                  
          expense items.                                                              
                                 d.  Contract Labor                                   
          Findings of Fact and Opinion                                                
               Petitioner claimed deductions for "contract labor", that is,           
          for secretarial help and other assistance, for each of the three            
          years at issue.  The amounts petitioner claimed, the amounts                
          respondent allowed, and the amounts respondent adjusted are as              
          follows:                                                                    
                                         1988       1989      1990                    
                    Per return12        $-0-      $17,921   $20,992                   
                    Per exam            -0-       10,720    17,474                    
                    Adjustment          -0-       7,201     3,518                     

               Respondent states on brief that petitioner was allowed a               
          deduction for those people for whom petitioner filed Forms 1099.            
               The $7,201 adjustment for 1989 consists of the following:              
                         Payee               Amount                                   
                         Joseph Clare        $1,355                                   
                         Gina Cagampan       3,110                                    
                         Shelly Jue          1,059                                    
                         Patrick Marason      800                                     
                         Miscellaneous       877                                      
                         Total               7,201                                    
               The 1990 adjustment consists of the following:                         
                         Payee               Amount                                   
                         Marilyn Yee         $420                                     
                         Patrick Marason     508                                      

          12  We have reduced these numbers by the amount of the contract labor       
          expenses dealt with under travel expenses.                                  




Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011