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people from the northern United States who came to Florida each
year for the winter and spring months. Petitioner conducted
services there twice weekly. Petitioner also taught at First
Baptist Church of Orlando, Florida, weekly and, in addition,
occasionally preached at various churches. All of petitioner's
sermons were prepared at his home office. No services or other
sacerdotal rites were performed at petitioner's apartment, nor
did he ever receive or counsel religious patrons there.
On his Federal income tax returns for 1993 and 1994,
petitioner's income and expenses from his insurance and
ministerial activities were combined and reported on Schedule C,
Profit or Loss From Business. The following income and expenses
were reported:
1993 1994
Gross income $20,144.89 $30,421
Expenses:
Advertising $502 $427
Car & truck expenses 13,990 16,828
Commissions & fees 661 --
Legal & professional 179 304
Office expenses 388 73
Taxes & licenses 86 --
Travel 4,106 4,977
Meals & entertainment:
80% 274 --
50% -- 152
Other expenses -- 2,313
Total 20,186.00 25,074
Tentative profit (loss) (41.11) 5,347
Expenses for business use of home -- 532
Net profit (loss) ($41.11)* $4,815
*Rounded to $42 on return.
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