- 3 - inter alia, car and truck expenses of $5,050 and legal and professional services of $13,870. In the statutory notice of deficiency, respondent disallowed the deduction for the employment agency fees because petitioners failed to show the expense was paid during the taxable year and that the expense was an ordinary and necessary business expense. As a result, petitioners’ remaining itemized deductions are less than the standard deduction of $6,900, which respondent accordingly allowed in lieu thereof. Respondent also disallowed petitioners’ Schedule C business deductions listed above because petitioners failed to show that they were eligible for them. On January 7, 2000, after the filing of the petition and the answer in this case, respondent served on counsel for petitioners requests for admissions. The requests set forth the following relevant matters: 5. The correct amount of petitioners’ miscellaneous itemized deductions for 1997 was zero ($0.00) as determined by respondent. 15. The correct amount of petitioners’ Schedule C car/truck expense for 1997 was zero ($0.00) as determined by respondent. 20. The correct amount of petitioners’ Schedule C legal/professional expense for 1997 was zero ($0.00) as determined by respondent. Petitioners never filed answers to the requests for admissions with the Court as required by Rule 90(c), and according to respondent’s undisputed assertion petitioners did not serve suchPage: Previous 1 2 3 4 Next
Last modified: May 25, 2011