Ahsan Mohiuddin - Page 25

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          sustain respondent's disallowance of the claimed deductions for             
          1992.                                                                       
               For the years 1991 and 1992 petitioner claimed to have                 
          incurred business expenses relating to "A & M Techservices".  He            
          claimed these deductions on Schedule C.  Respondent denied all of           
          these claimed business deductions for 1991 on the basis that                
          petitioner had not established that he was carrying on a trade or           
          business to which the expenses related.                                     
               Section 162(a) provides that there is allowed as a deduction           
          all ordinary and necessary business expenses incurred during the            
          taxable year.  Generally, a trade or business is an activity that           
          is pursued in good faith, with continuity and regularity, and for           
          the production of income.  Commissioner v. Groetzinger, 480 U.S.            
          23, 35 (1987).  Whether a taxpayer is engaged in a trade or                 
          business is a question of fact.  Walliser v. Commissioner, 72               
          T.C. 433, 437 (1979).                                                       
               Petitioner reported on his tax return for 1991 that the name           
          of his business was "A & M Techservices".  At trial, petitioner             
          claimed he was an engineering consultant, seeking to contract out           
          his services as an independent contractor.  He reported no gross            
          income in 1991 from this business, but claimed deductible                   
          expenses totaling $23,505.  Petitioner has placed in evidence               
          numerous canceled checks and other documentation in purported               
          support of these claimed deductions.  These checks relate to rent           
          payments, utility and phone bills, mailboxes, credit card                   




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