Marvin Ziporyn - Page 5

                                          5                                           
          Dues and subscriptions                   500                                
          Telephone                              4,043                                
          Total                             $22,893                                   
          Petitioner did not maintain any books or records with respect to            
          his practice.                                                               
               Petitioner reported income and expenses related to being a             
          musician on a separate Schedule C which is not at issue.                    
               In the notice of deficiency, respondent determined that                
          petitioner was not entitled to claim the following Schedule C               
          expense deductions totaling $11,172 for lack of substantiation:             
          Amount                                                                      
          Expense                         Disallowed                                  
          Car and truck expense            $1,523                                     
          Rent                                                                        
          Other business property           831                                       
          Travel                            5,651                                     
          Meals and entertainment           1,011                                     
          Telephone                         2,156                                     
          Respondent completely disallowed petitioner's claimed Schedule A            
          deductions for unreimbursed employee expenses for lack of                   
          substantiation.  Respondent further determined that petitioner's            
          home for tax purposes was California and that the disallowed                
          expenses represented nondeductible personal and commuting                   
          expenses.  Respondent also determined a computational increase in           
          petitioner's self-employment taxes as a result of the above                 
          adjustments.                                                                
               At the end of trial, the Court requested that the parties              
          file a supplemental stipulation of facts setting forth the                  
          expenses which petitioner claimed to have incurred, to be                   





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Last modified: May 25, 2011