Harout and Manik Gapikia - Page 2




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          expenses claimed on Schedule C, Profit or Loss From Business,               
          beyond those allowed by respondent.                                         
                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioners resided in                   
          Clifton, New Jersey, at the time the petition in this case was              
          filed.                                                                      
               In 1996 petitioner Harout Gapikia (petitioner) was employed            
          as a car salesman by Bob Ciasulli Auto Mall, Inc. and Hudson                
          Toyota Inc.  His combined wage income from these two employers              
          was $62,4151 in 1996.  Petitioner also received $1,150 from                 
          Toyota Motor Sales USA, Inc. in 1996 for selling extra items,               
          such as undercoating and alarm systems, to car buyers.                      
               In addition, petitioner offered sales training programs to             
          car dealerships and attempted to arrange for the export of cars             
          to other countries.  Petitioner, however, did not have any gross            
          receipts from these activities.                                             
               Petitioners filed a joint 1040, U.S. Individual Income Tax             
          Return, for their 1996 taxable year.  Petitioners claimed the               
          following job expenses on their Schedule A:                                 







               1  All numbers have been rounded to the nearest dollar.                




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