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and kept no ledgers or other accounting records concerning the
activity.
On his 1996 amended Schedule C, Profit or Loss From
Business, petitioner reported the following:
Gross receipts $1,209
Cost of goods sold 1,020
Gross income 189
Less:
Advertising $580
Car expenses 1,890
Insurance 400
Mortgage 6,540
Other interest 1,368
Rent 1,680
Repairs 1,250
Taxes 250
Utilities 1,296 15,254
Loss 15,065
The amount deducted as a “mortgage” expense in 1996 was for rent
petitioner paid in Alexandria. None of the other items were
specifically identified. For the 1997 taxable year, petitioner
filed electronically, and the only figure in the record is a
claimed Schedule C loss deduction in the amount of $10,174.
Respondent disallowed the deduction claimed for each year.
Discussion
A. Dependency Exemptions and Filing Status
Section 151(c) allows a taxpayer to deduct an exemption
amount for each dependent as defined in section 152. Section
152(a) defines a dependent, inter alia, as a brother or mother
“over half of whose support, for the calendar year in which the
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