- 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.
Background
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