Terry and Kathryn A. Roditski Dilozir - Page 3

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          the office of RE/MAX Realtors, located in Farmington,                       
          Connecticut.  On Schedule C for the 1993 tax year, petitioner               
          reported income and expenses as follows:                                    
          Amount    Total Amount                                                      
          Income:                                                                     
          Gross receipts                       $8,638.00                              
          Other income                          1,950.00                              
          $10,588.00                                                                  
          Expenses:                                                                   
          Advertising                           2,287.65                              
          Bad debts                             1,000.00                              
          Depreciation                          1,760.00                              
          Employee benefit programs               562.15                              
          Insurance                               850.00                              
          Office expense                        5,445.55                              
          Pension and profit-sharing plans        525.00                              
          Rent or lease                         3,521.23                              
          Repairs and maintenance                 874.32                              
          Supplies                                743.56                              
          Taxes and licenses                    1,515.00                              
          Travel, meals, entertainment            157.14                              
          19,241.60                                                                   
          Net loss                                      1(8,653.60)                   
               1  Petitioners' return miscalculated expenses as totaling              
          $18,431.60, resulting in total losses claimed in the amount of              
          $7,753.60.                                                                  
          In the notice of deficiency, respondent disallowed the claimed              
          rent expense in the amount of $3,521.23, and the claimed bad debt           
          deduction in the amount of $1,000.                                          
               Section 162(a) provides that there shall be allowed as a               
          deduction all the ordinary and necessary expenses paid or                   
          incurred during the taxable year in carrying on any trade or                
          business.  Section 6001 requires that a taxpayer liable for any             
          tax shall maintain such records, render such statements, make               





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