- 15 - II. Schedule A Versus Schedule C Deduction Disallowance All of respondent’s proposed adjustments decrease expenses claimed on the Schedule C and, correspondingly, increase petitioners’ adjusted gross income for 1994. Petitioners claim that, based upon “guidelines set out in audits of prior years”, they treated a portion of the expenses listed on the Schedule C as Schedule A itemized deductions on the premise that the expenses were associated with Randall’s wages from Wells Fargo Bank rather than with his own financial planning business. In fact, an attachment to line 46 of the Schedule C lists “other expenses”, totaling $76,180, and reduces the total by $39,084 which, instead, is deducted on line 20 of the Schedule A as unreimbursed employee expenses. Petitioners argue that, because a portion of the expenses listed on the Schedule C was, in effect, not taken on the Schedule C but taken, instead, on the Schedule A, a portion of the disallowance of those deductions should, likewise, be a disallowance of the itemized deductions reflected on line 20 of the Schedule A.5 Respondent argues that 5 Although petitioners do not indicate the tax benefit to be derived from their requested reattribution of a portion of respondent’s proposed deduction disallowances, we surmise that one such benefit is the resulting reduction in the loss of petitioners’ itemized deductions under sec. 68(a)(1) and (b), which, for 1994, equals 3 percent of petitioners’ adjusted gross income in excess of $111,800. By restoring deductions to Schedule C, petitioners reduce adjusted gross income and, thereby, reduce their loss of itemized deductions under sec. 68(a)(1) and (b). There is also an increase in petitioners’ (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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