Dale H. Sundby and Edith Littlefield Sundby - Page 7

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          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.                       





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