Wing Yiu Kwan - Page 5




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          Schedule C, petitioner reported, in pertinent part, the following           
          items of income and expense:                                                
               Income:                                                                
               Gross receipts                $   150                                  
               Gross income                  150                                      
               Expenses:                                                              
               Car and truck                 $ 2,802                                  
               Depreciation/sec. 179         19,632                                   
               Rent or lease                 2,100                                    
               Travel                        1,800                                    
               Meals and entertainment1      300                                      
               Utilities                     1,400                                    
               1  Petitioner reported meals and entertainment expenses of             
               $300 but, pursuant to sec. 274(n)(1), claimed a                        
               deduction for only $150 of such expenses.  Under                       
               sec. 274(n)(1), a deduction is allowable for only 50                   
               percent of meals and entertainment expenses incurred.                  


          After deducting various other Schedule C expenses not at issue,             
          petitioner reported a net loss from Partners of $29,409.                    
               In the notice of deficiency, respondent disallowed three of            
          the four dependency exemption deductions and determined that                
          petitioner failed to report gross receipts of $43 in connection             
          with Partners.  Respondent also disallowed the following amounts            
          of the Schedule C expenses:                                                 

               Car and truck                 $ 2,500                                  
               Depreciation/sec. 179         17,479                                   
               Rent or lease                 1,400                                    
               Travel                        1,800                                    
               Meals and entertainment       300                                      
               Utilities                     180                                      





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