Eli and Karen Yecheskel - Page 3

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          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.                                                            




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