Michael R. and Sheila Olsen - Page 3




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               Petitioners filed a joint Federal income tax return for                
          taxable year 1996.  With this return, petitioners filed a                   
          Schedule C, Profit or Loss From Business.  This schedule named              
          petitioners as proprietors of a business (“the Schedule C                   
          business”) engaged in “Mgt, Consulting, Estimating, Bkpr”.                  
          Petitioners reported the following amounts on this schedule:                
               Gross receipts or sales                      $10,645                   
               Cost of goods sold                           (500)                     
               Expenses                                                               
                    Advertising                   $500                                
                    Bad debts                     500                                 
                    Car and truck                 3,053                               
                    Depreciation                  2,446                               
                    Insurance                     250                                 
                    Office                        250                                 
                    Rent or lease                 1,500                               
                    Repairs and maintenance       2,000                               
                    Supplies                      250                                 
                    Utilities                     240                                 
                    Total expenses                          (10,989)                  
               Loss                                         (844)                     
          No income was reported on the Schedule C as having been received            
          from Olray Corporation for services rendered by petitioners.  In            
          the statutory notice of deficiency, respondent disallowed the               
          deductions for the car and truck, depreciation, and repairs and             
          maintenance expenses.                                                       
               Petitioners argue that the Schedule C business was engaged             
          in a variety of business activities, one of which was making                
          deliveries for Olray Corporation.  Petitioners testified that               
          they maintained separate office space on the premises of Olray              
          Corporation for conducting the activities of the Schedule C                 
          business, and that the business ventures were separate and                  





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