Robin Adams - Page 4

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          reflecting information such as payee names and amounts paid.  The           
          adjacent or facing page reflects totals by expense category such            
          as electricity, telephone, shop expenses, rent, and office                  
          expenses.  Petitioner then applied percentages to certain                   
          expenses such as electricity, heat, insurance, and telephone                
          because the amounts paid reflected the total usage for his                  
          household including personal use.  Petitioner claimed deductions            
          for business expenses at a rate of approximately 50 percent of              
          the amounts paid for utilities for the house.  The yearend total            
          page includes expenses which are not recorded on the monthly                
          logs.  For example, rent expense is shown as 40 percent of                  
          petitioner's total house payments of $11,400, or $4,560 for 1990,           
          but no rent expense is shown for any particular month during that           
          year.  Petitioner estimated certain expenses such as fuel                   
          expense, which he approximated as $100 per month.                           
               During 1990, petitioner traveled to Hawaii.  Petitioner                
          claimed a portion of the expenses from this trip as business                
          related.  Petitioner traveled to Antwerp sometime in 1991 to tour           
          a diamond cutting facility, and petitioner claimed expenses from            
          this trip as a business deduction.  Petitioner provided no                  
          records of these expenses.                                                  
               Petitioner and his former wife filed joint Federal income              
          tax returns for 1990 and 1991 and reported combined total wages             
          in the respective amounts of $38,253 and $47,310.  Petitioner               
          also reported pension and annuity distributions from Tektronics             




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