Randall and Lynn Bishop - Page 15




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         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...)           





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