Walter R. Strohmaier - Page 7




                                        - 7 -                                         

               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              





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011