Joyce H. Sams - Page 22




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          Accordingly, respondent’s determination on this issue is                    
          sustained.                                                                  
          5.  Schedule E Expenses                                                     
               Respondent disallowed deductions for a commission expense,             
          insurance expenses, association dues, a utility expense, and $290           
          of the painting expense claimed on Schedule E of petitioner’s               
          individual return, for a total of $1,246 of disallowed                      
          deductions.                                                                 
               Petitioner produced copies of canceled checks, bills, and              
          invoices to substantiate her claimed commission expense,                    
          association dues, and painting expense.  We are satisfied that              
          petitioner has provided credible evidence relating to the claimed           
          commission expense of $288, the dues expense of $188, and the               
          painting expense of $652, and she is entitled to deduct these.              
          Petitioner has not provided any credible evidence substantiating            
          the claimed insurance expenses of $471 or the claimed utility               
          expense of $9.  Accordingly, the claimed deductions for insurance           
          expenses and utility expense are disallowed.                                
          6.   NOL Carryover                                                          
               On her 1996 tax return petitioner claimed an NOL carryover             
          of $56,699 from her 1991 tax year.  Petitioner produced a copy of           
          the first page of her individual 1991 Federal income tax return,            
          which reflects a negative adjusted gross income of $25,803.                 
          Petitioner claims that the NOL from 1991 was not eliminated by              






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