Harry J. Sullivan - Page 2




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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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