- 4 - Business, realty advertising and auto expenses for 1996 and 1997 were reduced to zero because they did not establish the expenses were paid during the taxable years and that they were ordinary and necessary to their business; (4) the Wards’ Schedule C video cost of goods sold and supplies expenses for 1996 and 1997 were reduced to zero because they did not establish they were paid during the taxable years and that they were ordinary and necessary to their business; (5) the Wards’ Schedule C video depreciation expenses for 1996 and 1997 were reduced to zero because they did not establish the basis of the assets, that the assets were depreciable, and that they were ordinary and necessary to their business; (6) the Wards’ Schedule E, Supplemental Income or Loss, income was increased by $407,362 for 1996 and $448,253 for 1997 because (a) the Wards’ trust arrangements were shams or grantor trusts, or alternatively due to assignment of income, (b) of income from a partnership, and (c) of failure to establish that $1,487 for 1996 from Video City Shepard and $4,576 for 1997 from Arctic Video City were losses the Wards sustained; (7) self-employment tax adjustments for 1996 and 1997; and (8) accuracy-related penalties for 1996 and 1997 due to negligence or substantial understatement of tax. In the notices of deficiency issued to ASI, GND, WT, and GNI (collectively, the trusts) respondent took protective,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011