- 4 - Unfortunately, because the materials did not fit under the requirements of building codes, petitioner could not sell the idea to investors. The cost of getting building codes revised was prohibitive. During 1999, petitioner wrote letters to individuals and entities in an attempt to cover the costs of obtaining building permits to build houses and to secure investors in order to begin manufacturing the building panels. During 1999, Sax-Brook did not pay any employees or officers to perform services for the business. Petitioner was not reimbursed by Sax-Brook for any expenses incurred by him in connection with the corporation during 1999. Sax-Brook did not file a corporate income tax return with respect to 1999 with the Internal Revenue Service. Respondent in the notice of deficiency, among other things, disallowed petitioner’s Schedule C deductions in full. Respondent determined that petitioner did not establish that the Schedule C expenses were ordinary and necessary business expenses and that he did not substantiate the expenses. Section 162(a) allows a deduction for all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. To be deductible as a business expense, the expenditure must relate to activities which constitute the current carrying on of an existing trade orPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011