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a self-prepared statement attached to petitioners' return reports
no gross receipts and claims the following expenses:
Car and truck expenses $97
Depreciation 13,428
Motor home $8,133
Motor home 4,777
Computer 518
Interest 5,579
Mortgage 1,757
Other 3,822
Office expense 193
Rental of vehicles, machinery,
& equipment 101
Travel, meals, & entertainment 231
After 50% limitation 115
Miscellaneous expense 40
Petitioners claimed a Schedule A deduction for unreimbursed
employee business expenses in the amount of $23,494, after the
section 67(a) limitation. In the statutory notice of deficiency,
respondent disallowed the claimed deduction. Petitioners
attached a Form 2106-EZ and a self-prepared statement which list
the claimed expenses, before the limitation, as follows:
Travel expenses $862
Repairs & maintenance 2,522
Various gifts 318
Computer & office supplies 29
Telephone 169
Tracstar Simulcasting, Inc #86-0692628 21,169
At trial and in their opening brief,6 petitioners made no
distinction between the claimed Schedule C trade or business
expenses and the claimed Schedule A employee business expenses.
Their accountant, Michael Klecka, was not called to testify as to
6 Petitioners did not submit a reply brief as they were
instructed to by the Court.
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Last modified: May 25, 2011