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petitioner picked up a cargo trailer from Knox Cartage and
delivered the cargo to an appointed destination somewhere in the
continental United States. Knox Cartage then dispatched
petitioner to pick up new cargo to be transported back to
Knoxville. Petitioner traveled approximately 130,000 miles
hauling cargo during 1994.
Petitioner’s 1994 Federal income tax return was due to be
filed on April 15, 1995. However, petitioner filed an Internal
Revenue Service (IRS) Form 4868, Application for Automatic
Extension of Time to File, for his 1994 return timely, extending
the filing date to August 15, 1995. Petitioner did not file for
or receive any additional extension of time for his 1994 return.
He filed his 1994 return on August 24, 1995.
Petitioner’s 1994 return included a Schedule C, on which
petitioner reported income and expenses from his trucking
activity. He reported $62,474 in gross income for 1994, total
expenses of $62,113, and a net profit of $361. The following
table shows the expenses petitioner claimed on Schedule C and the
adjustments by respondent in the notice of deficiency with
respect to each item:
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