- 2 -
Respondent determined a deficiency of $7,041 in petitioners’
1999 Federal income tax.
The issue for decision is whether petitioners are entitled
to deductions claimed on a Schedule C, Profit or Loss From
Business, form.
Some of the facts in this case have been stipulated and are
so found. Petitioners resided in Milford, Massachusetts, at the
time they filed their petition.
Because petitioners have not complied with the
substantiation requirements of section 7491(a)(2), the burden of
proof as to facts relevant to the deficiency remains on
petitioners. Rule 142(a).
Petitioners timely filed their joint Form 1040, U.S.
Individual Income Tax Return, for 1999.
During 1999, petitioner Elliot Saffran (petitioner) operated
a “data processing” business. On Schedule C, petitioner reported
gross receipts of $90,038, total expenses of $70,562, and a net
profit of $19,476. Petitioner claimed Schedule C deductions for
car and truck expenses of $6,905, employee benefit programs of
$8,328, pension and profit-sharing plans of $12,113, and “other
expenses” of $8,741. The $8,741 amount comprised $3,645 for a
computer, $1,726 for software, and $3,370 for parking fees and
tolls.
Respondent disallowed $3,243 of the claimed car and truck
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011