Tod McMullen and Robin Everson - Page 6




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          The deduction for advertising relates to expenditures for 35mm              
          film, film processing, and photocopying.  The deduction for car             
          and truck expenses relates to mileage driven on a 1993 Mazda MPV,           
          the cost of which was deducted in a prior year under section 179.           
          The depreciation and section 179 deduction includes the costs of            
          the 1993 Pontiac Grand Am, the 1972 Dodge Van, and the computer             
          printer.  The deduction for insurance relates to automobile                 
          insurance on petitioners’ automobiles.  The deduction for office            
          expense includes expenditures for magazine and newspaper                    
          subscriptions.  The deductions for rent and utilities relate to             
          home office expenses.  The deduction for taxes and licenses                 
          relates to registration fees for petitioners’ automobiles.  The             
          deduction for other expenses relate to the cost of driving the              
          Mazda MPV on a trip described by petitioner as follows:                     
               It was a scenic trip, San Diego [where petitioners                     
               lived at the time], customer in Bakersfield, customer                  
               in - - no, that was it, the guy was in Bakersfield.                    
               The guy that had been a diesel engine rebuild mechanic                 
               who gave us a great reference.  He was in –- he was                    
               moving to Iowa, so I outfitted him, and that was in                    
               part of the gross sales –- no, wait, I –- he didn’t                    
               have any money, so I sold it to him on credit and never                
               collected, come to think of it.                                        
          The net loss claimed on the Schedule C offset other income                  
          reported on petitioners’ return.                                            
               In the notice of deficiency, respondent disallowed the                 
          deduction for the net loss.                                                 








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