- 7 - he conducted under the name Hawthorne Enterprises, Mr. Hawthorne deposited $1,000 every other month into a checking account in the name of Hawthorne Enterprises. Petitioners claimed in Schedules C of their returns for 1992, 1993, and 1994 expenses that Mr. Hawthorne incurred under the name Hawthorne Enterprises totaling $13,337.59, $13,098.76, and $9,981.94, respectively. Included in the expenses claimed in Schedule C for 1992 were $716.32 for "Legal and professional services", $2,775.04 for "Taxes and licenses", and $3,106.06 for "Depreciation". Included in the expenses claimed in Schedules C for 1993 and 1994 were $3,621.18 and $2,064.25, respectively, for "Taxes and licenses" and $3,106.06 for "Depreciation". In Schedules E of their 1992, 1993, and 1994 returns, petitioners reported rental income and various expenses with respect to certain real properties listed in those schedules, including $549.32 claimed in Schedule E of their 1992 return for "Legal and other professional fees" with respect to property identified as "315 Princeton S E, Albq". Notices of Deficiency In the notice of deficiency (notice) issued to petitioners for 1992, respondent, inter alia, disallowed all of the expenses that petitioners claimed in Schedule C of their return for that year because respondent determined that those expenses were not incurred in the operation of a trade or business. However, respondent allowed petitioners to include those disallowed Schedule C expenses as Schedule A deductions subject to appropri-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011