James A. and Corlis L. Perry - Page 8

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          Petitioner actually paid $3,399 in interest on his home mortgage.           
          On Schedule A, petitioner admittedly claimed a deduction of                 
          $4,902 for home mortgage interest.  On the editor Schedule C,               
          petitioner admittedly deducted another $500 for home mortgage               
          interest.  These unwarranted deductions amount to a deduction for           
          home mortgage interest of $2,003 more than petitioner was                   
          entitled to deduct.  Petitioner also deducted car and truck                 
          expenses of $4,000 on the editor Schedule C which related to                
          three personal vehicles used by petitioner to commute to his job            
          with Collegiate Services.  In addition, petitioner deducted a               
          payment to repair one of his personal automobiles.  Thus,                   
          petitioner’s use of the Schedules C allowed him to claim                    
          deductions for many nondeductible personal expenses and greater             
          deductions than were otherwise allowable.                                   
               With respect to petitioner’s purported Schedule C                      
          activities, petitioner has not proved that he was engaged in                
          either activity with a profit objective.  Petitioner did not                
          carry on either activity in a businesslike fashion.  With respect           
          to both activities, petitioner had no books, records, or business           
          plans.  Petitioner’s gross income for his tutor Schedule C and              
          his editor Schedule C consisted solely of wages he received in              
          his capacity as an employee of Collegiate Services and Carey                
          College, respectively.  Petitioner had no gross receipts with               
          respect to either activity.  Petitioner deducted personal                   
          expenses nondeductible under section 262 on his Schedules C.                
          Petitioner claimed unwarranted deductions for home mortgage                 





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