Steven and Jennie Jacobs - Page 13

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            5.    Office Expenses of $6,360                                                               
                  The office expenses listed on the 1992 Schedule C allegedly                             
            consisted of payments to Washoe Association for Retarded                                      
            Children, for which petitioner had previously worked as an                                    
            employee, of $5,000 for graphics equipment2 and $1,360 for office                             
            supplies.  The $5,000 allegedly consisted of a $2,500 lump-sum                                
            payment in cash that petitioner made to the Association and a                                 
            $2,500 credit in exchange for his services.  Petitioner testified                             
            that he did not include in income the $2,500 credit for services                              
            performed.  This was a barter exchange; failing to include the                                
            $2,500 credit in income prevents petitioner from obtaining a tax                              
            basis in the property received and therefore disentitles him to a                             
            deduction for the value of his services or the cost of the                                    
            property received.  See Barter v. Commissioner, T.C. Memo. 1990-                              
            142; Salon v. Commissioner, T.C. Memo. 1980-77.                                               
                  We find petitioner's testimony to be generally credible with                            
            respect to his cash payments for the equipment and supplies.  We                              
            allow a deduction of $3,860 for the purchase of equipment and                                 
            supplies.                                                                                     
            6.    Travel Expenses of $1,829                                                               
                  Petitioner has completely failed to meet the recordkeeping                              
            and substantiation requirements of section 274(d) for the claimed                             

                  2 Respondent did not determine or argue that any payments                               
            that petitioner persuaded the Court he had made should be                                     
            capitalized and deducted under sec. 167 or sec. 168.                                          




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