John Shackelford Fairbanks - Page 4




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          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 and                 






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