-4- Schedule C for those returns that he has filed. For the years at issue3 the relevant figures are: 1988 1989 1990 1991 Total Gross receipts $1,811 $1,539 $474 $434 $4,258 Cost of goods sold 552 942 323 0 1,817 Deductions 9,218 28,235 27,451 27,364 92,268 Profit (Loss) (7,959) (27,638) (27,300) (26,930) (89,827) Petitioner received an extension for filing his 1988 Federal income tax return until October 15, 1989, and filed that return on December 7, 1990. Petitioner received an extension for filing his 1989 return until October 15, 1990, but never filed that return. Petitioner received an extension for filing his 1990 return until October 15, 1991, but never filed that return. Petitioner received an extension for filing his 1991 return until October 15, 1992, and filed that return on October 19, 1992. Respondent determined that petitioner's artist activity was not engaged in for profit and therefore disallowed all of the deductions claimed attributable thereto. Alternatively, respondent determined that petitioner failed to substantiate the deductions or to prove that the expenditures were ordinary and necessary to either his artist or accounting activity and accordingly disallowed all of the claimed deductions. In accordance with this determination, respondent also reclassified 3The Schedule C figures for the artist and accounting activities for 1989 and 1990 are taken from Forms 1040 that petitioner provided during the course of respondent's examination of petitioner's 1988 through 1991 taxable years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011