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Beck had unreported income and that Dr. Beck is entitled to a
corresponding deduction for the community property split of his
income, as follows:
Year Amount
1991 $154,829
1992 147,095
1993 1159,121
1994 1207,057
1995 226,869
1 As previously described, it appears that for
1993 and 1994 respondent has overstated the amount of
Dr. Beck’s Schedule C income, thus resulting in an
overstatement of the amounts of community property
income for 1993 and 1994. We expect these errors to be
corrected in the Rule 155 computation.
Respondent disallowed entirely the Schedule F farm losses
that Dr. Beck claimed for 1993, 1994, and 1995, on the ground
that Dr. Beck had not established that each claimed loss
“constitutes an ordinary and necessary business expense, was
expended, or was expended for the designated purpose.”
Respondent also disallowed the NOL carryforward deductions that
Dr. Beck claimed for each year in issue, on the ground that Dr.
Beck had “neither established * * * [his] entitlement under the
Internal Revenue Code to [claim] a net operating loss nor
substantiated the amount of any loss.”
OPINION
Dr. Beck’s Schedule C Deductions
For each year in issue, respondent disallowed a portion of
Dr. Beck’s claimed Schedule C expenses as described above.
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