- 2 - $79 allowed by respondent for “research and development”; (2) a $5,328 rent deduction claimed out of $6,660 paid for use of an apartment in connection with petitioner’s writing activity; and (3) of $4,369 claimed as a deduction for supplies in connection with petitioner’s retreat activity, any more than the $666 allowed by respondent.1 By reason of petitioner’s failure to substantiate the deductions claimed, we sustain respondent’s determinations. Section references are to the Internal Revenue Code in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. For clarity and convenience, following a short initial background statement, the findings of fact and discussion with respect to the separate issues have been combined under separate headings. Background Some of the facts have been stipulated and are so found. The stipulations of fact and the accompanying exhibits are incorporated by this reference. Petitioner resided in Hemet, California, at the time he filed his petition in this case. 1 It is not clear from the record whether the deduction for supplies allowed by respondent was over and above the amount respondent allowed as an offset to the $2,336 of gross income that petitioner received from retreat participants. This question should be resolved in the Rule 155 computation.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011