- 2 -
After a concession by respondent that petitioners are not
liable for the accuracy-related penalty under section 6662(a) for
1995, we must decide whether petitioners are entitled to deduct
claimed Schedule C expenses of $26,860 and $4,800 in 1995 and
1996, respectively.
Some of the facts have been stipulated and are so found.
Petitioners resided in Decatur, Georgia, at the time the petition
was filed.
Petitioner Harold L. Dozier was a welder, and petitioner
LaCheer A. Dozier was a laundry worker. For 1995, on a Schedule
C listing Public Pay Telephone/Long Distance Services as the
principal business, petitioners claimed a loss of $24,500. On
that Schedule C, petitioners claimed total deductions of $26,860
as follows: commissions and fees - $17,500, legal and
professional services - $650, office expenses - $4,200, rent or
lease: vehicles, machinery and equipment - $4,200, supplies -
$310. For 1996, on a Schedule C listing Long Distance/
Information Services as the principal business, petitioners
reported a gain of $8,386. On that Schedule C, petitioners
claimed a deduction of $4,800 for rent or lease: vehicles,
machinery and equipment. Respondent disallowed the Schedule C
deductions of $26,860 for 1995 and $4,800 for 1996 on the grounds
that it was not established that any of the amounts claimed were
for ordinary and necessary business expenses or were expended for
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011