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B. Petitioner's Individual Income Tax Return for 1999
A Schedule C was also attached to petitioner's Form 1040 for
1999. Petitioner reported gross receipts of $21,600 and contract
labor costs of $19,400. Petitioner deducted depreciation of
$7,056; tuxedo dry cleaning expenses of $1,124; car and truck
expenses of $1,919; office expenses of $576; supplies expense of
$496; and utilities of $948.
Respondent disallowed deductions for all of the car and
truck expenses and all of the contract labor expenses due to lack
of substantiation. Respondent also determined that petitioner is
liable for an addition to tax under section 6651(a)(1) for
failure to timely file his 1999 return.
C. Petitioner's Individual Income Tax Return for 2000
Petitioner's Schedule C for 2000 again reflected gross
receipts of $21,600 and contract labor costs of $19,400.
Petitioner also deducted $7,980 for depreciation; car and truck
expenses of $5,327; office expenses of $444; supplies expense of
$503; utilities of $960; and tuxedo dry cleaning expenses of
$1,124.
Respondent disallowed deductions for all of the dry cleaning
and car and truck expenses as well as all of the contract labor
and depreciation expenses due to lack of substantiation.
Respondent also determined that petitioner is liable for an
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