- 4 - records pertaining to the Schedule C activities remained with the former husband. Petitioner attempted unsuccessfully to obtain those records. The revenue agent who conducted the audit determined that petitioner was entitled to relief as an innocent spouse under section 6015(f). That determination was overruled on review. The reviewer decided that she had knowledge of the understatement and had not established any hardship. The Appeals Officer adopted that recommendation. Discussion Schedule C Deductions Section 162(a) allows a deduction for all ordinary and necessary expenses incurred in carrying on a trade or business. Section 274(d), however, provides that no deduction is allowed for certain expenses unless the taxpayer “substantiates by adequate records or by sufficient evidence corroborating the taxpayer’s own statement”, inter alia, the time and place of the travel and the business purpose of an expense. The deductions that fall within section 274(d) include travel expenses, sec. 274(d)(1), and deductions “with respect to any listed property (as defined in section 280F(d)(4)”, sec. 274(d)(4). Included within the ambit of “listed property” are passenger automobiles and “computer or peripheral equipment”. Sec. 280F(d)(4)(A). There is an exception for computers and peripheral equipment usedPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011