Randall and Lynn Bishop - Page 4




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          Petitioners reported the results of the financial planning                  
          business on the Schedule C.  Petitioners computed the taxable               
          income of the financial planning business under the cash receipts           
          and disbursements method of accounting.  The Schedule C reports             
          gross receipts of $424,497 and net profit of $203,020.                      
               In part, respondent’s determination of a deficiency in tax             
          results from the following adjustments (disallowances) of                   
          deductions claimed on the Schedule C:                                       
                         Depreciation        $34,726                                  
                         Meals & entertainment    40,000                              
                         Office expenses          24,091                              
                         Rental expenses          18,247                              
                         Travel                   17,584                              
                         Seminars                 15,260                              
                         Presentations            12,675                              
               On brief, petitioners concede the following:  (1) the                  
          correctness of respondent’s disallowance of any deduction for               
          travel, (2) the correctness of a portion of respondent’s                    
          disallowance of a deduction for depreciation, (3) the correctness           
          of a portion of respondent’s disallowance of a deduction for                
          office expenses, (4) that the amounts claimed for “seminars” and            
          “presentations” are amounts paid for meals and entertainment,               
          which are subject to the 50-percent disallowance rule of section            
          274(n), and (5) the correctness of a portion of respondent’s                
          disallowance of a deduction for meals and entertainment                     
          (including the amounts claimed for “seminars” and                           
          “presentations”).                                                           






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