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earned income credit of $2,353 and, ultimately, a refund of $591
(i.e., $2,353 less $1,762).
In support of his claims of the earned income credit for
1999 and 2000, petitioner attached to his return for each of
those years a Schedule EIC, Earned Income Credit/Qualifying Child
Information. On each Schedule EIC, petitioner claimed his son,
Chinedu N. Ogu, as a qualifying child and represented that
Chinedu lived with him for the entire year.
I. Respondent’s Notice of Deficiency
For 1999, and as relevant to the issues for decision,
respondent disallowed the following deductions claimed by
petitioner as “other expenses” on Part V of his Schedule C:
Deduction Amount Claimed Amount Allowed Amount Disallowed
Depreciation $15,743 --- $15,743
EDI fee, advertising,
telephone, etc. 9,113 $1,489 7,624
Trade mission 11,900 --- 11,900
Overseas expenses 24,720 --- 24,720
For 2000, and as relevant to the issues for decision,
respondent disallowed the following deductions claimed by
petitioner as “expenses” on Part II or as “other expenses” on
Part V of his Schedule C:
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