Herbert Donald Singer - Page 8




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          ministry”.  On his return, petitioner reported passive income               
          from several sources in the aggregate amount of approximately               
          $65,000 (exclusive of tax-exempt interest and Social Security               
          benefits), and he claimed certain losses, including a “business             
          loss” in the amount of $38,923 from his “health, wealth and                 
          healing ministry” activity.  Petitioner reported a total tax                
          liability of $441 on his return.                                            
               In support of his claimed “business loss”, petitioner                  
          attached to his return a Schedule C, Profit or Loss From                    
          Business, for his “health, wealth and healing ministry” activity.           
          Petitioner reported no income on his Schedule C.  In contrast,              
          petitioner claimed expenses in the aggregate amount of $38,923,             
          consisting of the following:                                                
               Car expenses                                  $4,403                   
               Legal & professional services                  4,851                   
               Supplies                                       1,487                   
               Meals and entertainment                          314                   
               Other expenses                                                         
                    Business storage/rental     $12,000                               
                    Postage                         291                               
                    Printing/copies                  93                               
                    Professional publications/                                        
                    books/tapes/seminars      15,021                                  
                    Telephone                       463      27,868                   
               Total expenses                                38,923                   
               According to petitioner, the deduction for “Business                   
          storage/rental” represented monthly rent of $1,000 paid to his              
          mother for a dwelling unit used to store his “ozone machines”,              
          “wigglers”, oriental “heat type things”, and other product and              
          material for his “health, wealth and healing ministry” activity.            





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