Juan G. Ibarra and Margarita Ibarra - Page 5

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          deduction for medical and dental expenses.  Of the $4,815                   
          deducted by petitioners for home mortgage interest, $4,146 was              
          allowed, and $2,788 of the $5,150 deducted as charitable                    
          contributions was allowed.  Of the $6,039 deducted as                       
          unreimbursed employee business expenses, $1,736 was allowed.  No            
          adjustment was made for the $753 in real estate taxes deducted by           
          petitioners.  Thus, of the total $20,514 claimed as deductions,             
          respondent allowed deductions of $9,423 and disallowed $11,091.             
          All the amounts disallowed were for lack of substantiation.                 
               With respect to Schedule C, involving petitioner's activity            
          as a minister, respondent's determinations were as follows, all             
          relating to expenses deducted:                                              

          Claimed on        Allowed by                                                
          Return          Respondent                                                  
               Car and truck                  $2,031            $2,031                
               Commissions and fees            1,048              -0-                 
               Insurance                         250               250                
               Seminars                        1,550               480                
               Robes, special gear, oils,                                             
          and incense                    1,205              -0-                       
               Educational, books, etc.        2,887               200                
               Totals                       $8,971            $2,961                  

          No adjustments were made to petitioners' reported gross income.             
          The deductions also were disallowed for lack of substantiation.             
          As a result of the Schedule C adjustments, respondent determined            
          that petitioner realized a net profit from his ministry, thus               
          resulting in a liability for self-employment tax under section              





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