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the $34,430 of expenses deducted on the Schedule A. Respondent
further acknowledged that petitioners presented documentation
substantiating the additional $7,542.84 of unreimbursed business
expenses that petitioners listed on the schedule presented at
trial.
We decide the deficiency issues in this case on the basis of
the record without regard to the burden of proof. Accordingly,
we need not decide whether the general rule of section 7491(a)(1)
is applicable in this case. See Higbee v. Commissioner, 116 T.C.
438 (2001).
Schedule C–Business Expense Deductions
Petitioner testified at trial that he should have filed a
Schedule C with the 1997 tax return. At trial, petitioner
presented a list of expenses that he asserts relate to the
production of the $2,250 of self-employment income. The list of
expenses that petitioner claims should have been reported on
Schedule C includes the following:
Pictures $ 600.00
Parking 20.00
Agent 450.00
Directories 190.00
Computer 750.00
Meals 306.00
Education 1,130.00
Dues 170.00
Phone 28.00
Supplies 18.00
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