Anand K. Verma - Page 5




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          D.   Notice of Deficiency                                                   
               Respondent, in his notice of deficiency, disallowed all                
          expenditures made after October 4, 1996 (including the 1997                 
          expenses), on the basis that the expenditures were the expenses             
          of Export rather than petitioner.                                           
               As to the pre-incorporation expenses, respondent disallowed            
          deductions for advertising, insurance, office expenses, and taxes           
          and licenses.  Respondent allowed petitioner a depreciation                 
          deduction of $138 for part of the office expenses.  Additionally,           
          respondent disallowed $216 for travel and $705 for utilities.               
          Respondent disallowed the pre-incorporation expenses on the basis           
          that petitioner failed to establish that the expenses incurred              
          before the date of incorporation were ordinary and necessary                
          expenses or actually expended.                                              
               Petitioner argued at trial that this Court should disregard            
          Export’s corporate form so that Export’s expenses may be claimed            
          on petitioner’s Schedule C.  Further, petitioner asserts that he            
          expended the amounts claimed, and that the deductions constituted           
          business expenses.  Respondent counters that this Court should              
          uphold the corporate form and deny all expenses in excess of the            
          amounts allowed by respondent in his notice of deficiency.                  
                                       OPINION                                        
               We first consider the disallowed Schedule C expenses which             
          represent post-incorporation expenditures.  We then consider the            






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