- 9 -
Schedule C of the amended return reflects the following
expenses attributable to petitioner's activities as a
"professor":
Expense Amount
Office expense $ 2,452
Travel 8,261
Meals and entertainment 27,291
Less: 20% limitation (5,458)
Phone--toll calls 442
Subscriptions 327
Research books 166
Total expenses 33,481
Petitioners reduced Schedule A expenses claimed on the amended
return by the amount of $33,332. Therefore, we assume that the
expenses claimed on Schedule C of the amended return consist of
the expenses claimed on Schedule A of the original return that
are attributable to petitioner's activities, as well as
additional expenses in the amount of $149.
Upon examination, respondent allowed $29,600 of the $33,332
in expenses claimed by petitioners on their original return in
relation to petitioner's activities.8 The notice of deficiency
does not address the additional expenses claimed on the amended
return in the amount of $149, and, accordingly, we deem
8 Petitioners claimed expenses in the amount of $59,736 on
Schedule A of their original return. Respondent has allowed all
of these claimed expenses, except for travel expenses in the
amount of $3,732, relating to petitioner's research and writing
activities. Petitioners have conceded this adjustment. See
supra note 2. Since $33,332 of the $59,736 in expenses claimed
is attributable to petitioner's research and writing activities,
respondent has allowed $29,600 of the claimed expenses relating
to these activities ($33,332 - $3,732 = $29,600).
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