Joe D. and Maura F. White - Page 5




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          recited above.  The return included a Schedule C, on which                  
          petitioners reported the following income and expenses:                     

               Gross income                            $4,995.03                      
               Expenses:                                                              
               Car & truck         $938.43                                            
               Depreciation         253.43                                            
               Other expenses       351.77                                            
               Home office          941.43                                            
               Total expenses                       2,485.06                          
               Net profit                              $2,509.97                      

          The return also included the schedule for self-employment taxes,            
          which amounted to $354.46.  Elsewhere on their return,                      
          petitioners claimed a deduction for one-half of the self-                   
          employment taxes allowable under section 164(f).  This tax return           
          was admitted into evidence at trial.  Even though the deficiency            
          determined in the notice of deficiency was based only on two of             
          the Forms 1099-MISC, totaling $3,667, petitioners conceded at               
          trial that their self-employment income totaled $4,995.03, based            
          on the three Forms 1099-MISC described earlier.                             
               At trial, respondent conceded petitioners' entitlement to a            
          deduction for the following expenses shown on petitioners'                  
          corrected 1999 income tax return:  (1) $100 of the $938.43 in car           
          and truck expenses; (2) $253.43 in depreciation; and (3) $351.77            
          in other expenses, leaving at issue $838.43 in car and truck                
          expenses and $941.43 claimed as expenses for the business use of            
          petitioners' home.                                                          






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