Inez T. Morin - Page 8




                                        - 7 -                                         

               On her second Schedule C for her Joyful Wedding business,              
          petitioner deducted a total of $12,871 in expenses.  The amounts            
          claimed and the rounded amounts respondent conceded are set forth           
          below:                                                                      
          Deductions            Respondent                                            
          Expenses             Claimed               Conceded                         
          Advertising         $3,725                  $3,508                          
               Bad debts               75                                             
               Office                 406                     438                     
               Bank charges           194                     113                     
               Licenses             7,996                   7,320                     
               Misc.                  267                      75                     
               Telephone              208                       -                     
          $12,871                 $11,454                                             
          Petitioner did not have any other credible evidence.  We find               
          that she is entitled to deduct $11,454 of expenses for the Joyful           
          Wedding business.                                                           
               Petitioner reported $9,240 as other income from notary                 
          public services.  Respondent determined that the $9,240 was part            
          of petitioner’s gross receipts for MBS and that it was subject to           
          self-employment tax.  Income from services as a notary public is            
          not subject to the self-employment tax.  Sec. 1402(c); sec.                 
          1.1402(c)-2(b), Income Tax Regs.  However, petitioner had no                
          records of a notary public business or any other evidence to show           
          she was entitled to exclude $9,240 from self-employment income.             
          When asked about her notary records, petitioner stated:  “It’s              
          just a lot of paperwork.  I didn’t bring that.  I didn’t bring              
          the details”.  She did have a notary seal.  Accordingly, we allow           





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