Richard A. Stasewich - Page 4

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          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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