Marie-Francine T. Grow - Page 5

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          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 used           






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