- 10 - dispute exists between the parties concerning whether the expense is properly characterized as contract labor expense or wage expense subject to employment taxes. Although petitioners raised this as an issue in their petitions to this Court, the parties stipulated that respondent had not issued a notice of determination concerning this issue and that it is not currently before this Court. See sec. 7436. As such, only the amounts paid to the individuals in 1996--not the characterization of the payments--is at issue. The amount of the payments was not addressed at trial, however, and nothing was produced to substantiate any such payments in excess of what respondent determined had been made. Petitioners have failed to substantiate any of the above alleged expenses as business expenses deductible under section 162(a). Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. We therefore sustain respondent’s disallowance of the deductions therefor. Finally, petitioner argues that he is entitled to an additional deduction which he claimed on an amended return form which he filed for 1995. Petitioner intended to use an amended return to make a variety of changes to amounts of income and deductions reported on the original 1995 return. These changes, resulting in a reduction of petitioner’s reported adjusted gross income from $80,867 to $11,582, were not accepted by respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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