William Herbert Whitehurst, III and Carla Cherlene Whitehurst - Page 6




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               Petitioners reported income and claimed deductions for                 
          expenses with respect to the bowling activity as follows:                   
                                             1997      1998       1999                
          Income:                                                                     
               Prize winnings           $3,052    $2,725         $889                 
               Expenses:                                                              
               Car and truck1             5,889     6,240     6,258                   
               Repairs and maintenance       703       605       542                  
               Supplies                      350       157       226                  
               Travel                   3,540     3,998     3,137                     
               Meals and entertainment       1,271     1,295     1,034                
               Other (entry fees)            8,700     7,968     7,415                
               Total expenses:              20,453    20,263    18,612                
               Loss                     (17,401)  (17,538)  (17,723)                  
                    1 Petitioners claimed deductions for the standard1                                                                
               mileage rate for the years at issue.                                   
               In the notice of deficiency respondent disallowed the                  
          claimed Schedule C deductions for 1997, 1998, and 1999 and                  
          determined that Mrs. Whitehurst did not engage in the bowling               
          activity for a profit.  Respondent asserts that the element of              
          personal pleasure is inherently present in the bowling activity.            
               As an alternative position in the notice of deficiency                 
          respondent disallowed the following claimed deductions:                     
                                         1997     1998      1999                      
               Car and truck       $2,532         $763      $894                      
               Supplies                 350       157       226                       
               Repairs and maintenance    703     605       542                       
               Travel              2,220    3,332     2,610                           
               Meals and entertainment   825      977       629                       
               Other (entry fees)      5,483    4,562     6,246                       
          Respondent disallowed the claimed deductions because either                 
          petitioners did not provide books and records reflecting the                







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