Stephen J. Cotta, Sr. - Page 6




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          clients, and any further revenue would be divided equally.  The             
          business had no office, but petitioner rented a mailbox in                  
          Modesto, California, for its use.  Clients would pay between $50            
          and $100 for the housekeeping services with the exception of one            
          client who was a cosmetic surgeon and who rendered payment in the           
          form of breast implant surgery.  The cost of goods sold claimed             
          on petitioner’s return in the amount of $750 was the cost of Ms.            
          Castillo’s housecleaning services rendered to clean petitioner’s            
          personal residence “to foster motivation and enthusiasm in Ms.              
          Castillo.”  This same expenditure was also claimed as a deduction           
          for wage expense.  The advertising expense of $6,000 consists               
          partly of advertising at a bar/restaurant during “Friday night              
          get-togethers with the local crowd” in which petitioner would               
          find out who needed housekeepers.  The remainder is non-                    
          advertising expense which was categorized improperly.  Petitioner           
          also purchased insurance and cleaning supplies for the business,            
          as well as a computer that was used over half the time for                  
          business purposes.  Finally, petitioner purchased meals while               
          traveling to look for clients.  The business was terminated when            
          Ms. Castillo’s boyfriend asked her to terminate her business                
          relationship with petitioner in order to foster their own                   
          personal relationship.                                                      
               We find that, at most, petitioner was in the process of                
          starting a business which never materialized.  However, assuming            






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