- 17 - j. Travel, Meal, and Entertainment Expenses Petitioners claimed travel, meal, and entertainment expense deductions in the amount of $6, subject to a 50 percent limitation on Schedule C of their 1994 Federal income tax return. Petitioners have not substantiated or explained this expense deduction and have not shown that this expense was incurred in carrying on a trade or business as required by section 162. We find that petitioners have not complied with the requirements of section 162 and hold that petitioners are not entitled to claim meals and entertainment expense deductions for the 1994 tax year. 2. Petitioners' 1995 Income As previously found, petitioners failed to file a Federal income tax return for the 1995 tax year. Using BLS data, respondent determined that petitioners each earned income of $19,775, as well as community interest income of $55 for the 1995 tax year. At trial, petitioner admitted that for 1995 the restaurant generated gross income in the amount of $83,083.90. Based on petitioner's admission, we find that the $83,083.90 amount is a more accurate measure of gross income than respondent's use of BLS data, and, therefore, we find that petitioners earned total gross income in the amount of $83,083.90 from the restaurant for the 1995 tax year.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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