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Feltrinelli to Mr. and Mrs. Owens.1 Respondent determined that
petitioners' tax returns should be changed as follows:
Mr. and Mrs. Owens
Adjustments to income &
expenses 1989 1990
Dependency exemption $2,000 $2,050
Schedule C expenses 75,257 50,570
Franchise fee income (5,000)
Sec. 482 allocation 27,569 32,235
Truck wash 3,330
Truck lift 2,220
Truck changer 1,250
Sale of alcoholic
beverages 99,662
Cost of goods sold -
Alcoholic beverages (76,663)
Self-employment tax
deduction (6,279)
Total $99,826 $108,375
1 On brief, respondent conceded that the adjustments under
sec. 482 do not apply.
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