- 4 -
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.
274(n).
For convenience, we shall combine our findings of fact and
opinion with respect to each disputed item.
Discussion
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
residence.
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