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We sustain respondent’s determination in the notice of
deficiency.
The second issue for decision is whether petitioner is (a)
entitled to deductions in addition to those claimed on his
return, and/or (b) entitled to recharacterize as business expense
deductions any of the itemized deductions that he claimed on his
return.2 Petitioner argues that he is entitled to the changes
which he made to his filed return on a Form 1040X, Amended U.S.
Individual Tax Return. Petitioner submitted this form to the IRS
in April 2003, following the issuance of the notice of deficiency
underlying this case. On the form, petitioner claimed a variety
of changes to the information on his original return. First, he
added a Schedule C, Profit or Loss From Business, on which he
claimed zero gross income and a loss of $28,379 for a business
named “Maritime Ventures” engaged in the business of “Antique
Dealer”. Petitioner also decreased his claimed itemized
deductions by $11,328 to $45,203, due in whole or part to his
recharacterization of certain expenses--which he claimed on his
original return as itemized deductions--as business expenses on
the Schedule C. Respondent has not accepted any amounts reported
by petitioner on the amended return.
2The recharacterization of itemized deductions as business
expense deductions would change petitioner’s AMT liability under
sec. 55(a).
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