Marvin Ziporyn - Page 4

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          California.  After that time, petitioner returned to Chicago,               
          Illinois.                                                                   
               For tax year 1990, petitioner reported on line 7 of his Form           
          1040 $37,945 in wages, comprising of $37,834.89 from the county             
          of Riverside, California, and $110 from TALCO Enterprises.  The             
          expenses incurred with respect to his California wage income were           
          claimed on line 20 of Schedule A as "unreimbursed employee                  
          expenses" in the amount of $11,660, before the 2-percent floor.             
          According to Form 2106, Employee Business Expenses, this total              
          consisted of $10,340 for travel expenses while away from home               
          overnight including lodging, airplane, car rental and other                 
          expenses, and $1,650 less 20 percent for meals and entertainment.           
               Petitioner reported income and expenses related to his                 
          Chicago, Illinois, practice on Schedule C.  Petitioner reported             
          gross receipts of $12,700 from his psychiatric practice.  This              
          figure was based upon petitioner's estimate of the number of                
          hours that he saw patients and the rate that petitioner charged             
          per hour.  Petitioner claimed the following expenses on Schedule            
          C:                                                                          
          Amount                                                                      
          Expense                               Claimed                               
          Car and truck expense                 $2,420                                
          Legal and professional services          240                                
               Rent                                                                   
          Other business property              5,600                                  
          Taxes and licenses                       600                                
          Travel                                 7,920                                
          Meals and entertainment                                                     
          $1,650 less 20 percent               1,320                                  
          Parking                                  250                                




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