Juan N. and Miriam J. Villareal, et al. - Page 17

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               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.                                                          






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