- 4 - activities in 1994, 1995, and 1996 on Schedules C, but reported $14,161, $16,389, and $12,533 of net Schedule C losses for the 1994, 1995, and 1996 tax years, respectively. On his Schedule C attached to his 1995 Federal income tax return, petitioner reported no gross receipts and claimed the following expenses: Advertising $91.27 Car/truck expenses 2,949.14 Depreciation/section 179 2,755.33 Supplies 131.21 Travel expense 229.17 Meals/entertainment 190.62 Other expenses 1,760.86 $8,107.60 Business use of home 8,281.35 Total expenses 16,388.95 In 1997, petitioner obtained a consulting contract with L Three Communications, a local aerospace company, but was not paid until 1998. In a notice of deficiency dated June 3, 1998, respondent determined that petitioner was not entitled to Schedule C expenses of $16,389 for the year in issue because he (1) was not engaged in an activity for profit pursuant to section 183, and (2) failed to substantiate his claimed 1995 Schedule C deductions. Respondent also determined that petitioner was entitled to additional itemized deductions for real estate taxes and interest expenses in the amount of $3,361 for 1995. As an initial matter, we deal with an issue raised by petitioner concerning respondent's conduct during audit andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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