Rilwan Adisa Salami - Page 5

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          did not take into account any tips, which would have increased              
          the total gross receipts up to 15 percent.  We have considered              
          petitioner's miscellaneous objections to Mr. Savage's                       
          calculations and, after carefully reviewing the record, are                 
          convinced that the cab formula used by Mr. Savage clearly                   
          reflects petitioner's gross receipts for 1992 and 1993.  We                 
          therefore sustain respondent's determinations of petitioner's               
          unreported income.                                                          
               The second issue for decision is whether petitioner is                 
          entitled to Schedule C business expense deductions in excess of             
          the amounts allowed by respondent.                                          
               Petitioner claimed a deduction for car and truck expenses              
          for 1992 in the amount of $16,200.  In the statutory notice of              
          deficiency, respondent disallowed $7,473 of the claimed expenses.           
          Petitioner also claimed a deduction for repairs to his taxicab              
          for 1993 in the amount of $3,055.  Respondent disallowed $1,644             
          of the claimed repairs.                                                     
               Respondent's explanations in the statutory notice of                   
          deficiency state that the amounts were disallowed because                   
          petitioner did not establish that any amounts over the allowed              
          amounts were ordinary and necessary business expenses, and that             
          the section 274 substantiation requirements had not been met.               
               Section 162(a) provides for the deduction of all ordinary              
          and necessary expenses paid or incurred during the taxable year             
          in carrying on any trade or business.  Deductions are strictly a            

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