- 3 -
Petitioner resided with her mother, Dorothy Carter, in a
home titled in her mother's name. Petitioner's mother received
Social Security payments during 1990 and paid the real property
taxes on the residence. Petitioner paid some of the expenses of
the home for herself and her mother.
Petitioner has a bachelor of science degree and a master's
degree and is certified to teach biology at the senior high
school level. During 1990, she worked full time as a teacher in
the District of Columbia public schools. Since 1979, petitioner
has operated a tutoring and counseling activity in the evenings
and weekends during the school year and full time during the
summer. Petitioner reported a loss from her tutoring and
counseling activity on Schedule C for each of her tax returns for
1979 through 1991.
Petitioner failed to maintain adequate records of her
expenses relating to her tutoring and counseling activity. For
1990, she claimed total expenses of $18,289, resulting in a loss
of $13,527. The claimed expenses included car and truck expenses
of $5,938, but petitioner did not keep a record of her business
mileage or other records from which business use of her
automobile could be determined. She incurred some expense for
supplies, photocopying, and typing, but she failed to keep
records to establish the amount of her deductions for those
items. When petitioner was asked to produce substantiation for
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011