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C. Automobile Expenses
For his work-related travel, petitioner estimated total
mileage for 1996 at 33,000 miles. Petitioner did not maintain a
log of work-related travel during 1996.
D. Home Office Expenses
Petitioner lived with his girlfriend and maintained a home
office in her house. Petitioner paid her $250 per week in cash.
Neither petitioner nor his girlfriend allocated a specific
portion of the weekly payment to particular expenses. Instead,
petitioner left it to his girlfriend’s discretion how the money
was to be used. Petitioner did not maintain receipts for any
home office expenses.
E. 1996 Tax Return
On April 15, 1997, petitioner timely filed his 1996 Federal
income tax return. On his 1996 return, petitioner claimed income
from insurance and other sales of $5,796 after Schedule C
deductions of $8,910 and $3,600 for automobile and office
expenses, respectively. Because of a move from Albuquerque, New
Mexico, to El Paso, Texas, petitioner never received the Forms
1099 issued for his income from American, Capitol, or Life USA
for his 1996 tax year.
Respondent issued a notice of deficiency to petitioner
regarding his 1996 tax year. In the notice of deficiency,
respondent determined, inter alia, that for the year 1996
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