- 8 -
allocation petitioner used to determine the amount of Schedule C
expenses. Therefore, we shall apply the Cohan doctrine to each
of the above expenses that petitioner asserts relate to the L.A.
Models Inc. job to decide the amount that should have been
claimed on Schedule C.
Unless an expense was directly incurred for the L.A. Models
Inc. job, the total business expenses reported on Schedule A
should be prorated according to the amount of time spent on the
particular job. Petitioner testified that he worked a total of
205 days in 1997. Petitioner further testified that the L.A.
Models Inc. job lasted 4 days. Therefore, 1.95 percent of
petitioner’s total days worked was spent on the L.A. Models Inc.
job. Accordingly, 1.95 percent of petitioner’s total business
expenses reported on Schedule A that relate to the L.A. Models
Inc. job are proper Schedule C expenses.
Of the above expenses that petitioner asserts relate to the
L.A. Models Inc. job, petitioner testified that the $20 for
parking, $450 for agent fee, and the $306 for meals were expenses
directly incurred during that job. Petitioner presented
documentation at trial to substantiate that the $450 agent fee
directly related to the L.A. Models Inc. job. Since petitioner
deducted expenses for parking on Schedule A that respondent
agrees were substantiated, we find that petitioner is entitled to
a Schedule C deduction of $20 for parking. Petitioner did not
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011