Mary K. Moylan - Page 3




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                              Claimed        Allowed        Disallowed                
          Auto/truck expenses $20,546        $13,560        $6,986                    
          Insurance expenses   3,244         394            2,850                     
          Legal expenses      2,250          -0-            2,250                     
          Office expenses     840            -0-            840                       
          Repair expenses     6,400          -0-            6,400                     
          Taxes/licenses      1,767          -0-            1,767                     
          Utilities           1,020          -0-            1,020                     
          Tolls               1,526          1,035     491                            
          Miscellaneous       902            -0-            902                       
          Test expense        150            -0-             150                      
               Except as discussed infra, petitioner presented no                     
          documentary evidence to support the deductions that were                    
          disallowed.  Petitioner's testimony concerning these items was              
          sparse.  Petitioner testified that the truck expenses ($20,546)             
          were for diesel fuel, but she had receipts for only $10,435.65.             
          With respect to the legal expenses, petitioner testified that               
          they were incurred in connection with selling the tractor, the              
          sale of which was completed in 1995.  Petitioner could not state            
          what the deduction for taxes was, although from her testimony it            
          appears that at least some part was paid to the Internal Revenue            
          Service.  The office expenses and utilities were for an alleged             
          home office; she did not know, however, how the expenses had been           
          allocated between the personal and business use of the residence.           
          Petitioner did not know what the miscellaneous expenses were for.           
          With respect to the repair expenses, petitioner agreed that some            
          of the claimed expenses were for her personal automobile.  With             
          regard to the "test" expense, this apparently was an expense for            







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