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In the notice of deficiency, respondent disallowed the
following expenses:
1993 1994
Car & truck $1,193 $1,239
Travel 4,056 4,927
Meals & entertainment 212 113
Expenses for business
use of home -- 532
As noted earlier, respondent made computational adjustments,
flowing from the above, to petitioner's self-employment taxes,
the deduction for one-half of such taxes, and the earned income
credit claimed by petitioner. As also noted earlier, petitioner
conceded at trial the $212 and $113 disallowed meals and
entertainment expenses claimed respectively for 1993 and 1994.
As shown above, petitioner claimed car and truck expenses of
$13,990 and $16,828, respectively, for 1993 and 1994. On
Schedule C of the return for 1993, petitioner based the $13,990
claimed on 49,302 business miles. Petitioner stated on the
return that he had no commuting mileage that year and 2,594
additional miles for other purposes. In the notice of
deficiency, respondent determined that petitioner had 45,702
business miles for 1993 instead of 49,302 miles claimed on the
return. Respondent allowed a deduction of $12,797 at the rate of
28 cents per mile and disallowed $1,193, the balance of the
amount claimed for 1993. On the 1994 return, petitioner based
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