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The issues in this case are: (1) Whether petitioner is
entitled to a Schedule C, Profit and Loss From Business, car and
truck expense deduction beyond that which respondent allowed; (2)
whether petitioner is entitled to a Schedule C depreciation
expense deduction beyond that which respondent allowed; and (3)
whether petitioner overstated Schedule C gross receipts.1 An
adjustment to the self-employment tax and deduction therefor is
computational and will be resolved by the Court’s holding on the
issues in this case.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Owings Mills, Maryland.
Petitioner has a doctorate in education. During 1996,
petitioner provided human resource consulting services through a
business entity known as E. Clark and Associates, a sole
proprietorship. Petitioner operated his business from his home.
Petitioner rendered services to governmental agencies. These
agencies issued purchase orders to petitioner. After completion
of the job an invoice was sent to the agency for payment.
1 Petitioner raised an additional issue in his petition:
Whether petitioner was entitled to Schedule A, Itemized
Deductions, in lieu of the standard deduction. This issue was
abandoned by petitioner at trial.
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