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withheld for 1998 as $3,120, and $730, respectively.
Petitioner properly reported $50,334 of wage income and
$2,199 of Federal income tax withheld on his 1998 return.
Petitioner claimed the $3,199.72 Social Security tax withheld and
the $729.91 Medicare tax withheld as a credit for excess Social
Security payments and as a credit for “other payment”,
respectively, on his 1998 return. Respondent disallowed these
purported credits.
Petitioner filed a Schedule C for his machine shop activity
as part of his 1998 return. During 1998, petitioner reported
gross income of zero with respect to his machine shop activity.
On his Schedule C, petitioner claimed the following deductions:
Expense Amount
Car and truck $575
Depreciation 4,859
Office expense 7,900
Rent or lease 200
Repairs and maintenance 99
Taxes and licenses 876
Utilities 295
Other expenses:
Membership/Dues 30
Bank 222
Trucking supplies, etc. 2,453
Trucking daily credit 10,255
Uninsured damages 2,082
Losses brought forward 13,532
Total 43,378
Respondent determined that all of the car and truck
expenses, trucking supplies expenses, and uninsured damages were
employee business expenses incurred by petitioner as a cross-
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