-6- evidence to support his claim, we are not convinced that petitioner's business expenses equaled or exceeded income during the years in issue. Nor are we convinced that the self- employment income reported on the information returns represents the total gross receipts of petitioner's business for each year.3 Petitioner asserts that he earned no income during the years in issue because all income from his business was earned and reported by Lorenzo Thomas. Petitioner testified that a back injury prevented him from doing any of the actual tile setting during the three years in issue. Therefore, petitioner asserts, Lorenzo Thomas performed all the tile setting and earned all the income from the business. Petitioner did not offer medical records or any other evidence to corroborate his claim that a back injury prevented him from working during the years in issue. We also note that during the audit of petitioner's returns he did not mention that he had a back injury and did not assert that Lorenzo Thomas earned all the income from the business. We hold that petitioner has failed to show that he had business expenses that equaled his income during the years in issue. Petitioner also contends that he did not make the personal expenditures attributed to him by respondent during the years in 3Section 6041(a) requires a payor to issue a Form 1099-MISC to a nonemployee payee (as well as to respondent) regarding remuneration for services only when such remuneration equals or exceeds $600 in any taxable year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011