Mary T. King and Fatai O. King - Page 8




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             the unreported rental and sale payments is $13,233, or                     
             $834 less than the amount determined in the notice of                      
             deficiency, $14,067.  Respondent acknowledges that the                     
             notice of deficiency should be sustained to the extent of                  
             the lesser amount, $13,233.  Accordingly, we find that                     
             petitioners’ gross income should be increased by unreported                
             rental payments of $2,400 and by unreported proceeds from                  
             the sale of the newsstand on Knox Street of $10,833.                       
                  We turn to the principal issue in this case, the                      
             expenses petitioners are entitled to deduct in connection                  
             with their newsstand business.  At trial, petitioners did                  
             not attempt to substantiate the expenses claimed on the                    
             Schedule C, Profit or Loss From Business, filed as part of                 
             their original return.  In fact, petitioner admitted that                  
             his original return was not correct.  Petitioner testified                 
             that his original return was “done by mistakes” and “was                   
             unintentionally done by me.”                                               
                  At trial, petitioners proceeded by attempting to                      
             substantiate the expenses claimed as deductions on the                     
             Schedule C attached to their amended return.  Petitioners                  
             claimed different expenses on their original return, on                    
             their amended return, and in their posttrial brief.  The                   
             following is a list of the expenses claimed by petitioners                 
             and the expenses conceded by respondent to be deductible:                  






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