Robert Walter Allison - Page 3

                                        - 2 -                                         
          petitioner is liable for a deficiency in petitioner’s Federal               
          income tax for the taxable year 1995 in the amount of $3,081.               
               After concessions made by respondent,1 the issue for                   
          decision is whether petitioner is entitled to deduct certain                
          Schedule C, Profit or Loss From Business, expenses in excess of             
          amounts allowed by respondent for the year in issue.  Adjustments           
          to the earned income credit, self-employment income tax and the             
          deduction therefor are computational and will be resolved by the            
          Court’s holding in this case.                                               
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner resided in Troy, Michigan.                            
               Petitioner is the sole proprietor of Allison Associates,               
          which is in the business of selling training equipment and                  
          supplies to public schools across the United States.  He has been           
          in the business of sales for more than 40 years.  During 1995,              
          petitioner operated Allison Associates out of his 1,050 square              
          foot, 2-bedroom apartment.  Petitioner had lived alone in the               
          apartment since about 1990, and it was not used to entertain                
          family or other guests.                                                     

               1    Respondent concedes that petitioner is entitled to $26            
          of the utility expense and $826 of the business use of home                 
          expense claimed on his Schedule C, Profit or Loss From Business.            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011