Raymond B. and Joan M. Marvin - Page 5




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          business plan, financial projections, and financial statements              
          for the activity.                                                           
               On the Schedule C attached to their 1996 Federal income tax            
          return, petitioners reported a net loss from Glacial Jadeite in             
          the amount of $18,440.  On the Schedule C, petitioners reported             
          no gross income and claimed substantial deductions for car and              
          truck expenses and rent.  The return also reflects claimed                  
          deductions for insurance, office expenses, repairs, meals and               
          entertainment, and miscellaneous expenses.  Included in the rent            
          expense, petitioners claimed home office expenses in the amount             
          of $9,600.  The home office expense consists of residential lease           
          payments that petitioners made in 1996.  For the year 1997,                 
          petitioners reported that the jade activity had gross receipts of           
          $50 and expenses of $18,578.85.  Petitioners claim that the jade            
          activity had gross receipts of $250 and expenses of approximately           
          $18,000 for the year 1998.                                                  
               Respondent determined that petitioners' jade activity was              
          not an activity engaged in for profit.  In the alternative,                 
          respondent determined that petitioners' claimed Schedule C                  
          expenses were personal expenses and not ordinary and necessary              
          business expenses.                                                          
               Section 183 provides that if an activity engaged in by an              
          individual is not engaged in for profit, no deduction                       
          attributable to such activity shall be allowed, except as                   






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