John Mosier and Sarah Spain - Page 6




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          deficiency deductions of $1,551, $3,553, and $2,563.  Respondent            
          concedes in his trial memorandum that petitioners should have               
          received current-year expense deductions5 of $3,102, $3,242, and            
          $1,992 in the notice of deficiency.  Respondent concedes in the             
          stipulation that petitioners are entitled to additional                     
          deductions of $992, $1,244, and $2,738.  Finally, respondent                
          conceded at trial the initial adjustment to the travel expenses             
          in 1993, thereby conceding that petitioners were entitled to a              
          deduction of $4,094 in the notice of deficiency.  Thus, under               
          respondent’s multiple concessions, petitioners are entitled to              
          deductions for travel expenses of $5,086 in 1993, $4,486 in 1994,           
          and $4,730 in 1995.                                                         
               The following table reflects items which remain at issue in            
          this case after the various concessions.  The amounts of                    
          deductions claimed by petitioners on their Federal income tax               
          returns are shown, along with the total allowances and                      
          concessions by respondent.                                                  
               1993             1994             1995                                 
               Allowed/         Allowed/                                              
          Allowed/                                                                    
               Claimed Conceded Claimed Conceded Claimed                              
          Conceded                                                                    
               Business expenses (Sch. C)                                             
               Writing/lecturing                                                      
               Interest expense        $5,342   $3,925  $6,845   $2,774  $11,303      
          $1,097                                                                      
               Travel expense                            6,355    4,486    6,790      
          4,730                                                                       
               Travel/writing/consulting                                              
               Travel expense                                              2,676    -0-
               Other expense                                                 725    -0-
               Itemized deductions (Sch. A)                                           
               Mortgage interest expense  12,853    8,6531                            
               Miscellaneous              10,202      856  11,998    5,626    9,147   
          1,709                                                                       

          5See supra note 3 regarding the issue of capitalization.                    


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