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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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Last modified: May 25, 2011