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Respondent determined that petitioner failed to substantiate
that certain deductions were ordinary and necessary expenses
incurred while carrying on a trade or business. We must decide
whether petitioner: (1) Is entitled to deduct on Schedule C,
Profit or Loss From Business, car and truck expenses and amounts
deducted as wages paid for casual labor in excess of those
allowed by respondent; (2) is liable for self-employment tax; and
(3) failed to file timely his Federal income tax return without
reasonable cause.
The stipulated facts and exhibits are incorporated herein by
reference. At the time the petition in this case was filed,
petitioner resided in Marietta, Ohio.
FINDINGS OF FACT
Petitioner filed his 1996 Form 1040, U.S. Individual Income
Tax Return, on April 19, 1999.
Petitioner was self-employed in 1996 as a subcontractor. He
performed work on windows, patios, patio doors, siding, and other
cosmetic work on houses. Petitioner drove a pickup truck with an
8-foot bed that he used to carry various pieces of equipment used
in his business. His work required him to carry "pump-jacks" for
scaffolding he used on homes, a "porta-brake" for metal bending,
ladder jacks, roof brackets, a 10-inch portable saw, and a table
saw. During 1996 petitioner drove from his home to job sites
located in West Virginia, Pennsylvania, Maryland, and Ohio.
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