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profession as computer and software, and his business activity
code as 443120, signifying a computer and software store.4
On his Schedule C for 1999, petitioner claimed various
deductions. As relevant to the issues for decision, those
deductions were as follows:
Other/Depreciation $15,743
Other/EDI fee, advertising,
telephone, etc. 9,113
Other/Overseas expenses 24,720
Other/Trade mission 11,900
On his Schedule C for 2000, petitioner claimed various
deductions. As relevant to the issues for decision, those
deductions were as follows:
Depreciation $4,157
Legal/Professional 3,270
Other/Used file cabinets,
chairs, and tables 7,840
Other/Overseas rent 3,900
Other/Overseas expenses 7,870
Other/Overseas wages 16,000
Other/Overseas office 1,680
Other/Trade mission 6,975
Petitioner did not attach to either of his returns for 1999
or 2000 a Form 4562, Depreciation and Amortization (Including
Information on Listed Property), or other depreciation schedule.
4 At trial, petitioner testified that Creative Accountants,
see supra p. 3, was a “dba” of Americana Business Consultants.
According to petitioner, “we divided our business for people to
identify what kind of business we are doing”.
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