Michael A. McCann - Page 4




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          condominium.  He reported that his dental equipment was located             
          at 324 N. Brooks, Brazoria, Texas.                                          
               During 1996, petitioner had various personal litigation                
          matters pending.  He also pursued claims of $98, $137, and $105             
          against three patients.  During 1996, he wrote checks to Dale               
          Morse (Morse) in the amount of $12,656.  Petitioner did not issue           
          a Form 1099 to Morse.                                                       
               Petitioner’s expenditures during 1996 were spread into                 
          various categories and deducted on his 1996 Federal individual              
          income tax return, primarily on two Schedules C, Profit or Loss             
          From Business.  Many expenses were mischaracterized.  For                   
          example, amounts paid for groceries were deducted as dental                 
          practice postage expenses.  All amounts paid on petitioner’s                
          credit card were deducted by him.  Many personal expenses of                
          petitioner were deducted.  Petitioner deducted as “contract                 
          services” payments made to his children in the amount of his                
          child support obligation.  Petitioner’s payments to his children            
          were not reasonable payments for services rendered by the                   
          children to petitioner’s business.  All of the expenses of the              
          condominium were deducted as dental lab expenses.  All of                   
          petitioner’s automobile expenses were deducted as business                  
          expenses.  Petitioner did not maintain adequate records of                  
          business use of the automobile or of the business purpose of                
          travel, meals, or entertainment expense deducted on his return.             






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