- 3 -
Statement-–Income Tax Changes; (5) a statement titled
“Explanation of Adjustments”; and (6) a statement titled “1998-
Schedule A-Itemized Deductions”.
In the Explanation of Adjustments, respondent described in
detail the following adjustments made to petitioner’s 1998 tax
return: (1) Contributions of $2,306.78 deducted on Schedule A
were disallowed for lack of substantiation; (2) miscellaneous
other expenses of $2,700.27 deducted on Schedule A were
disallowed for lack of substantiation, failure to establish that
the expense was ordinary and necessary, and failure to establish
that the expense qualifies as a miscellaneous other expense
pursuant to the Internal Revenue Code (Code); (3) other
miscellaneous deductions of $4,074.36 for section 691 expense
deducted on Schedule A were disallowed for lack of substantiation
and failure to establish that the expense qualifies as an other
miscellaneous deduction pursuant to the Code; and (4) interest
expense of $4,665.21 deducted on Schedule C was disallowed for
lack of substantiation, failure to establish that the expense was
ordinary and necessary, and failure to establish that the expense
qualifies as interest pursuant to the Code.
On the Statement–-Income Tax Changes, respondent increased
petitioner’s taxable income by the disallowed amounts described
above and revised petitioner’s taxable income for the year at
issue. In accordance with the revised taxable income, respondent
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011