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expenses while away from home; and $3,600 meals and
entertainment.
Petitioners’ Schedules C reported that they were in a
“telecommunications” business known as “Today’s Enterprises”.
Petitioners reported no gross receipts from this business during
1992 or 1993 but claimed the following expenses:
Items 1992 1993
Advertising $ 240.00 --
Car and truck expenses 2,200.00 $ 11,080.98
Office expense -- 1,718.62
Rent
Vehicles, machinery, and
equipment 3,120.00 5,800.00
Other business property -- 9,600.00
Supplies 4,417.92 --
Travel
Meals and entertainment 7,200.00 12,000.00
Enter 20% of line 24b
subject to limitations 1,440.00 2,400.00
Subtract line 24c from
line 24b 5,760.00 9,600.00
Utilities 1,277.66 --
Other expenses
Equipment 2,054.00 1,705.00
Publications 635.87 --
Tentative profit (loss) (19,841.45) (39,504.60)
The amounts claimed as losses on Schedules E attached to
petitioners’ returns for 1992 ($4,900) and 1993 ($9,600)
represented $700 per month in 1992 and $800 per month in 1993
allegedly owed to petitioners by Today’s Enterprises for rent
beginning June 1992. Petitioners claimed the loss as rent not
received because Today’s Enterprises had no income. At least as
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