Ilya G. and Sophia K. Margolis - Page 5




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               In addition, in the corrected return petitioners decreased             
          their personal exemptions by one, resulting in an increase in               
          petitioners' taxable income in the amount of $2,300.  Petitioners           
          also submitted a "corrected" Schedule C for Mr. Margolis'                   
          business, conceding a $4,413 reduction in Schedule C expenses.              
          As part of the claimed expenses in the corrected return, Mr.                
          Margolis also claimed an $890 mortgage interest expense                     
          deduction.5  Respondent allowed this $890 deduction for Mr.                 
          Margolis' business.                                                         
          Subsequently, respondent conceded that Mrs. Margolis had                    
          received only $14,180 of unreported self-employment income from             
          her textile design business, as opposed to $14,755 as determined            
          in the deficiency notice, and that petitioners were entitled to             
          $1,535 in Schedule C expense deductions for Mrs. Margolis'                  
          business.  Respondent did not allow a deduction for the $890                
          mortgage interest expense for Mrs. Margolis' business or for the            
          $4,502 home office expense.                                                 
               At trial, respondent asserted an increase to petitioners'              
          unreported income resulting from two different adjustments to               
          respondent's bank deposits analysis.  First, respondent's counsel           
          determined that petitioners deposited only $1,500 of Mrs.                   
          Margolis' self-employment income, as opposed to $4,470 as                   


          4(...continued)                                                             
          to a mortgage expense.                                                      
          5  It appears that petitioners similarly intended to claim a                
          deduction for an interest expense as opposed to a mortgage                  
          expense.                                                                    

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