- 3 - and personal care products, principally aloe vera products from the Living Products company. Petitioners reported the hauling activity and the retail sales activity on a single Schedule C for each of the taxable years 1993 and 1994. Ruby also operated a rooming house during the taxable years at issue. Petitioners purchased the rooming house on January 29, 1993. The signature date of each petitioner on their 1993 return is June 4, 1994. Petitioners' 1993 return was mailed to the Internal Revenue Service (Service) in an envelope bearing the date June 7, 1994. The Service received petitioners' 1993 return on June 13, 1994. Petitioners did not request an extension of the date to file their 1993 return. Respondent, inter alia, adjusted petitioners' gross receipts, adjusted the costs of goods sold attributable to Ruby's business, and disallowed in whole or in part many Schedules A and C deductions. Respondent disallowed some claimed expenses because it was not established that the expenses were paid or incurred during the taxable year, and that they were ordinary and necessary, or because it was not established that a business benefit could reasonably be expected as the result of incurring entertainment expenses. Respondent also determined that petitioners were subject to self-employment tax. Deductions are strictly a matter of legislative grace. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); NewPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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