- 3 -
by respondent. Resolution of this issue requires a
detailed review of the pleadings and other papers filed by
the parties.
In determining the above deficiencies in petitioners'
tax, respondent disallowed the following deductions claimed
on the subject returns:
1986 1987 1988 1989 1990
Schedule C
Travel and
entertainment $8,176 $7,839 $12,843 $15,878$25,217
Depreciation expense 1,545 -0- -0- -0- -0-
Meals and
entertainment -0- 2,328 3,961 7,490 4,422
Bad debts -0- -0- -0- 5,500 -0-
Advertising 207 738 -0- -0- -0-
Commissions 2,171 3,246 4,899 5,537 7,101
Insurance 575 1,899 2,045 1,310 1,598
Employee business
expense 29,943 -0- 19,896 -0- -0-
Itemized deductions 2,500 2,530 (1,278) (734) 2,580
Miscellaneous
deductions -0- 22,088 -0- -0- 13,300
Total adjustments 45,117 40,668 42,366 34,981 54,218
Respondent disallowed the above deductions principally because
petitioners had failed to substantiate their eligibility for
the deductions.
The initial petition in this case was in the form
of a typed letter to the Court, which states as follows:
TO WHOM IT MAY CONCERN:
In re my telephone conversation with your office
today, please accept this letter as my petition
for redetermination of the deficiency shown on
the attached copy of notice. Please send me the
pertinent petition forms, as well as available
information, to the address shown below:
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Last modified: May 25, 2011