Kenneth and Sheila Smith - Page 5

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          officers.  The after-tax amounts of petitioner's bonus payments             
          were credited against the debit balance in the personal expense             
          account.  In other words, the bonus payments were used to repay             
          the amount owed by petitioner to Tracstar for personal expenses             
          charged to the Corporate card and the Gold card.  The total                 
          amount credited to the personal expense account in this manner              
          during 1994 was $21,798.66.  Tracstar's balance sheet dated                 
          December 31, 1994, shows a debit balance in the personal expense            
          account in the amount of $20,289.68.                                        
               Petitioner ceased working for Tracstar in January 1995.  He            
          disputes his liability for some of the charges which Ms. Parsons            
          characterized as personal expenses and debited to the personal              
          expense account.  Litigation over the amounts payable by                    
          petitioner and Tracstar was ongoing at the time of the trial in             
          this case.                                                                  
               Petitioners filed a joint Federal income tax return for                
          1994.  Their return was prepared by Tracstar's accountant,                  
          Michael Klecka.  Petitioners reported the total of petitioner's             
          regular ($65,000 = 26 payments times $2,500) and bonus                      
          compensation ($31,680 = 11 payments times $2,880) from Tracstar             
          as wages and other compensation on petitioners' 1994 return.                
               Petitioners claimed a Schedule C business loss deduction in            
          the amount of $19,553.  In the statutory notice of deficiency,              
          respondent disallowed the claimed deduction.  The Schedule C and            






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