Dieter Stussy - Page 3




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          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           






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