Florence C. Blankson - Page 13




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          which are not deductible under section 262.  As to the                      
          documentation that represented business expenses, petitioner                
          failed to establish that the receipts that related to deductible            
          expenses were not already allowed in the notices of deficiency by           
          respondent.  Consequently, for the years 1993 and 1994, the Court           
          sustains respondent on the disallowed Schedule A and Schedule C             
          expenses.                                                                   
               Petitioner’s critical care nursing activity for 1995 and               
          1996 needs to be considered separately for the following reason.            
          The parties stipulated that petitioner earned “only W-2 wages”              
          during 1995 and 1996, which implicitly suggests that petitioner             
          did not earn any income in her self-employed critical care                  
          nursing activity during these 2 years.  In the notices of                   
          deficiency, respondent did not allow or concede any deductions              
          for trade or business expenses for this activity for 1995 and               
          1996.  Nonetheless, in spite of the stipulation referred to,                
          petitioner reported gross receipts of $4,684 and $8,173,                    
          respectively, for 1995 and 1996, on Schedule C of her returns for           
          those years in connection with her critical care nursing                    
          activity.  In the notices of deficiency, these income amounts               
          were not removed, and all of the claimed expenses were                      
          disallowed.  The Court concludes that the stipulation of the                
          parties on this issue is in error, since petitioner did earn                
          gross income during 1995 and 1996 from her critical care nursing            





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