Friscia Construction, Incorporated, et al. - Page 18




                                       - 18 -                                         
         action does not relieve taxpayers of their duty to file a timely             
         return.  See Chamberlin v. Commissioner, T.C. Memo. 2000-50.                 
              Accordingly, we hold that Michael Friscia is liable for the             
         section 6651 addition to tax with respect to the net amount of tax           
         due on his 1995 tax return.                                                  
         Issue 6.  Friscia Construction’s Allowable Deductions                        
              Respondent’s notice of deficiency denied all of Friscia                 
         Contruction’s costs of goods sold and deductions for the taxable             
         year ended June 30, 1995 (the 1995 taxable year).  On brief,                 
         respondent concedes that Friscia Construction is entitled to costs           
         of goods sold and deductions of $108,160.                                    
              Friscia Construction claimed costs of goods sold on its 1995            
         taxable year corporate tax return of $222,264 along with the                 
         following deductions:                                                        
              Accounting                         $650                                 
              Truck expense                      5,393                                
              Misc.                         111                                       
              Dues                               486                                  
              Equipment rental                   55                                   
              Union dues                    1,204                                     
              Insurance                          4,713                                
              Office                             345                                  
              Postage                            64                                   
              Telephone                          5,682                                
              Utilities                          1,105                                
              Supply                             1,501                                
              Bank charges                       132                                  
              Promo                              430                                  
              License                            96                                   
                                  ------                                              
              Total deductions       21,967                                           








Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011