George Coloney - Page 5

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          Schedule C Expenses                                                         
               Petitioner claimed the following expense deductions on                 
          Schedule C of his 1994 Federal income tax return:                           
               Supplies expense                   $6,500                              
               Taxes & licenses                   49,000                              
               Travel                             16,500                              
               Meals and entertainment            14,400                              
               Other expenses                     21,450                              
               Total                         107,850                                  
               Petitioner has produced a New York Statement of Income Tax             
          Adjustment for 1994 (New York income tax adjustment) and an                 
          undated, handwritten New York State Estimated Income Tax Payment            
          Voucher for the 1994 taxable year (Estimated Income Tax Voucher)            
          in connection with the amount claimed as a deduction for State              
          income taxes.  The New York income tax adjustment shows that                
          petitioner estimated his 1994 New York State income tax liability           
          to be $25,000 when he submitted Form IT-370, Application for                
          Automatic Extension of Time to File for Individuals, and had                
          $2,610 withheld in New York State income tax for the 1994 taxable           
          year which respondent has allowed as an itemized deduction on               
          Schedule A of petitioner's 1994 Federal income tax return.  The             
          New York State Department of Taxation and Finance determined that           
          petitioner made an overpayment of $27,610 for the 1994 taxable              
          year but applied the overpayment to other liabilities.                      
               Petitioner has submitted copies of his 1994 American Express           
          Card statements to establish travel, meals, and entertainment               
          expenses.                                                                   




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