Karan M. Hintze - Page 4

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          Similarly, after concessions,2 the following items remain in                
          dispute with respect to petitioner’s 1994 tax year:                         

                                   Reported by  Determined by    Amount in            
                  Item             Petitioner     Respondent      Dispute             
          Gross receipts            $44,126        $52,259         $8,133             
          Home office expense         1,230          -0-            1,230             
          Traveling expense           8,531            347          8,184             
          Meal expense1                 280          -0-              280             
          Laundry expense               596            260            336             
               1  Figures are net of the 50-percent reduction required by sec.        
          For convenience, we shall combine our findings of fact and                  
          opinion with respect to each disputed item.                                 
          A.   Gross Income                                                           
               Petitioner reported gross receipts from her sole                       
          proprietorship on Schedule C of $17,177 and $44,126 for tax years           

               2  Petitioner concedes respondent’s determination as to the            
          amount of the deduction for car and truck expenses.  Petitioner             
          also concedes respondent’s determination as to the amount of the            
          deduction for supplies expense.  With respect to the deductions             
          for advertising and telephone expenses, petitioner appears to               
          concede respondent’s determination by incorporating the figures             
          determined by respondent into her posttrial brief.  To the extent           
          these items are not conceded, we sustain respondent’s                       
          determination with respect to these items as petitioner failed to           
          introduce evidence to the contrary.  See Rules 142(a), 149(b);              
          Pearson v. Commissioner, T.C. Memo. 2000-160.                               
               Respondent concedes the deductions claimed by petitioner for           
          interest expense and rent expense.  Respondent also concedes that           
          petitioner is entitled to $347 of the $8,531 deduction for                  
          traveling expenses claimed by petitioner.                                   
               Finally, the parties have stipulated that petitioner                   
          recognized $8,104 in capital gain upon the sale of her principal            

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