- 6 - trade or business expenses in 1994.1 The notice of deficiency states: It is determined that the amount of $89,069.00 as a loss from an information services business for the taxable year ended December 31, 1994 is not allowed because you did not establish that such an activity constitutes a bona fide business entered into for profit. Further, it has not been established that the claimed expenses were incurred or, if incurred, paid by you during the taxable year for ordinary and necessary business purposes or that any claimed amount qualifies as an allowable deduction under the provisions of the Internal Revenue Code. Further, it has been determined that the claimed Schedule C expenses are start-up expenditures and not deductible in the taxable year ended December 31, 1994 under section 162 of the Internal Revenue Code. Further, it has been determined that the claimed Schedule C expenses were not your expenses but those of the corporations, Search 2000 and Navis Communications. Accordingly, with the disallowance of all of your Schedule C expenses and home office expenses taxable income is increased $89,069.00. Because the Schedule C expenses were disallowed, respondent also determined that petitioners are not entitled to the NOL carryback from 1994 to 1991. The entire amount of the 1991 deficiency of $26,783 results from the disallowance of the NOL carryback and related computational adjustments. With respect to 1994, respondent also determined that income of $866 received by petitioner wife from Personalized Workout of La Jolla, Inc., is subject to self-employment income tax. This adjustment gives rise to the entire amount of the 1994 deficiency of $122. Despite stating a general objection to the 1994 deficiency in 1In lieu of the home office expense deduction of $22,169, respondent allowed petitioners additional itemized deductions for taxes and mortgage interest totaling the same amount.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011