-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.
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