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The third issue is whether petitioners are entitled to
deductions for other Schedule C expenses, for 1994, 1995, and
1996, in excess of amounts allowed by respondent. The remaining
Schedule C expenses for each of the years at issue mainly
constitute expenses in connection with petitioner’s business
activities at Memphis and Nashville, Tennessee, as well as
certain other various business expenses. The amounts disallowed
by respondent are as follows:
Expense 1994 1995 1996
Car & truck $3,840.61 -- $1,722.89
Legal & prof. 980.00 $2,920.00 468.54
Office –- –- 125.10
Rent or lease 5,500.00 5,832.62 6,595.00
Supplies –- –- 441.11
Travel 7,627.35 6,669.83 3,752.40
Meals & ent.1 385.39 1,385.75 306.31
Other 22,027.29 33,263.81 41,292.48
1 Prior to the 50-percent limitation.
2 Consists of $751.35 for equipment, $147.39 for
miscellaneous, $358.55 for parking, and $770.00 for dues &
publications.
3 Consists of $1,965.39 for lodging and $1,298.42 for
miscellaneous.
4 Consists of $35.32 for dues & publications, $814.14 for
lodging, $90.65 for miscellaneous, $190.40 for parking, and
$161.97 for shipping & postage.
7(...continued)
petitioner wife and were written on petitioners’ joint checking
account. Petitioners produced no evidence to show that this
cellular phone was used in connection with any business activity
of petitioner.
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