- 3 - employed activity. Petitioners filed a Schedule C, Profit or Loss From Business, with their 1992 return that described petitioner's activity as research and development. At trial, petitioner testified that he was the creator of software for internet use relating to national health information and patient care management. He presented a lengthy list of clients, from all parts of the United States, which included doctors, hospitals, medical schools, scientific institutions, health organizations, academies, and government or quasi-government agencies. On the 1992 Schedule C of their return, petitioners reported $500 gross income from petitioner's activity, expenses of $16,053, and a net loss of $15,553. In the notice of deficiency, respondent disallowed all the expenses claimed but allowed petitioners a deduction of $510 for telephone expenses that petitioner had substantiated during the audit process. The telephone expenses allowed had not been claimed on petitioners' 1992 return.3 The expenses claimed by petitioners on their Schedule C, which respondent disallowed, are the following: 3 The adjustment in the notice of deficiency of $15,543 is based upon a disallowance of all the expenses claimed, $16,053 less $510 allowed for telephone expenses, which petitioners had not claimed on the return. Respondent did not reduce the $15,543 by the $500 gross income reported for the reason that petitioners failed to establish that any of the expenses claimed had been paid or incurred.Page: Previous 1 2 3 4 5 6 7 Next
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