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Type of Expense Amount Claimed
Vehicle $10,096*
Business 3,450**
Meals and
Entertainment 7,000***
Miscellaneous 11,250****
Total $31,796
* Includes claimed travel mileage (miles x 28 cents),
parking fees, tolls, and other local transportation.
** Not explained.
*** Includes claimed expenses associated with the Club
(after statutory 2-percent floor).
**** Includes claimed expenses associated with periodicals,
clerical help, and legal advice regarding investment
matters.
On audit, with regard to petitioner's 1991 Federal income
tax return, respondent refused to allow petitioner to
recharacterize the $37,767 bonus as nontaxable loan proceeds.
Based on petitioner's lack of investment income, respondent
disallowed petitioner's claimed $5,433 investment interest
expense deduction for 1991. Respondent also determined that,
based on calculations resulting in a tentative minimum tax
equaling $33,080 and a regular income tax equaling $22,807,
petitioner was subject to the alternative minimum tax (AMT) and
owed additional income tax thereunder.
Also for 1991, respondent determined an addition to tax for
petitioner's failure to timely file his Federal income tax
return.
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Last modified: May 25, 2011