George A. and Christine M. Evan - Page 4

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          in issue.  On their 1997 tax return, petitioners claimed a                  
          deduction for Schedule C business expenses of $17,809, consisting           
          of advertising expenses, car and truck expenses, office expenses,           
          taxes and licenses, and travel expenses.  Petitioners listed Mr.            
          Evan’s profession on the Schedule C as a “Licensed Real Estate              
          Broker & State Certified Appraiser”.  Petitioners reported no               
          income on the Schedule C from any business activities.                      
               On petitioners’ tax return for 1998, Mr. Evan listed his               
          occupation as “Professor”, and Mrs. Evan listed her occupation as           
          “Claims Authorizer”.  Petitioners claimed a deduction for                   
          Schedule A unreimbursed employee expenses of $31,445, consisting            
          of parking fees, tolls, transportation, travel expenses, business           
          expenses, union and professional dues, professional                         
          subscriptions, and job search costs, but reported no wages from             
          Mr. Evan’s occupation as a professor.  Petitioners reported wages           
          from Mrs. Evan’s employment with the Social Security                        
          Administration.  Petitioners also claimed a deduction for                   
          Schedule C business expenses of $6,752, consisting of advertising           
          expenses, car and truck expenses, depreciation, office expenses,            
          expenses for supplies, and travel expenses.  On the Schedule C,             
          Mr. Evan listed his principal business as “RE Broker, Appraiser”            
          but did not report any income from any business activities.                 
               Mr. Evan did not have interviews scheduled for any of the              
          job-hunting trips for which petitioners claimed expense                     






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