- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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