Richard William Corduan - Page 11




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          only that he “would say United Way got some” and that he also               
          made contributions to his church.  He could not recall the exact            
          amounts of such contributions.  In the absence of any written               
          records or other substantiation for the charitable contributions,           
          we uphold respondent’s disallowance of the deductions therefor.             
               The next item at issue is petitioner’s entitlement to                  
          certain limited liability company (LLC) losses.  Petitioner                 
          claimed partnership losses of $21,600 and $20,763 in 1996 and               
          1997, respectively, for an LLC.  Respondent disallowed these                
          losses in full.                                                             
               An LLC with more than one member is treated as a partnership           
          for Federal income tax purposes unless the LLC elects otherwise.            
          See sec. 301.7701-3, Proced. & Admin. Tax Regs.                             
               The LLC in which petitioner was a member did not file a                
          partnership return in either year.  In 1996, petitioner filed a             
          Schedule E, Supplemental Income and Loss, reflecting a                      
          partnership loss.  In 1997, petitioner completed a Schedule C,              
          Profit or Loss From Business, and then claimed approximately 56             
          percent of the net loss reported on this form as his distributive           
          share of the LLC’s loss.  Petitioner presented no evidence to               
          support the claimed losses or the underlying expenses listed on             
          the Schedule E or C.  Furthermore, at least a portion of the                
          expenses listed on the schedules, if actually incurred, were not            
          related to any business.  For example, legal and professional               






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