Darl N. and Bonnie S. Miller - Page 3




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              The amount claimed by petitioners as a credits report                   
         deduction on Schedule C2 of their return in the amount of                    
         $28,610 was reduced to the amount of $25,283 because the                     
         amounts disallowed were determined to be nondeductible and/or                
         personal in nature.                                                          
              The amount claimed by petitioners for business                          
         development on Schedule C2 of their return in the amount of                  
         $20,932 was disallowed because that amount was determined to                 
         be a personal expenditure.                                                   
              The amount claimed by petitioners as cost of loans on                   
         Schedule C2 of their return, in the amount of $24,706 was                    
         reduced to $8,579.  The amount disallowed ($16,127) was                      
         determined to be nondeductible and/or personal in nature.                    
              The amount claimed by petitioners for contract labor on                 
         Schedule C2 of their return, in the amount of $13,228 was                    
         reduced to $11,920 because the amount disallowed ($1,308) was                
         determined to be personal in nature.                                         
              The amount claimed by petitioners for costs of funds on                 
         Schedule C2 of their return in the amount of $12,886 was                     
         disallowed because the amount claimed was determined to be                   
         loan payments and/or other nondeductible items.                              
              In a report dated October 25, 1996, respondent's                        
         examining agent noted that petitioners' accountant had                       
         prepared a general ledger for 1993 from information provided                 
         by petitioners.  Upon examining the various accounts contained               
         in the ledger, the examining agent opined that a number of                   


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