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entitled to deduct various expenses claimed on their Schedule C
in excess of the amounts allowed by respondent. Petitioners
resided in Dallas, Texas, at the time their petition was filed.
Ronald L. Miller (petitioner) is engaged in the business of
tax preparation and consulting, doing business under the name of
Express Tax Service. He holds an associate degree in arts and
science with an accounting emphasis from Eastfield College, and a
bachelor of science degree in accounting from the University of
Texas at Dallas. On January 15, 1989, petitioner commenced a 1-
year lease of an office located at 8541 Ferguson Road in Dallas,
Texas. The terms of the lease provided for a monthly rent of
$535, to be increased to $650 if the lease was renewed, and
utilities to be paid by petitioner. According to petitioner, at
the conclusion of the lease, he and his landlord, referred to in
the record only as Dr. Cantrell, orally agreed to renew the lease
for 1 year and to maintain the rent payments of $535. There is
no written documentation of this agreement.
On the Schedule C filed with his 1990 return, petitioner
claimed deductions for various business expenses including $1,188
for rental of a printer, $6,420 for rent of the office space,
$2,544 for utilities, and $2,764 for the cost of a software
program. In the notice of deficiency, respondent disallowed each
of the above deductions for lack of substantiation.
We begin by noting that, as a general rule, the
Commissioner's determinations are presumed correct, and the
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