- 16 - Finally, we address a point petitioners raised at trial. Petitioners assert that the explanation in the notice of deficiency regarding the disallowance of the Schedule C expenses was too vague to allow for an adequate response. We agree that the explanation as a whole suffers from a certain lack of clarity or specificity. However, the notice of deficiency in effect sets forth several alternative theories under which respondent determined that petitioners are not entitled to any of the Schedule C deductions. The Commissioner generally is permitted to set forth alternative grounds for adjustments in a notice of deficiency, as well as to take alternative positions at trial. Doggett v. Commissioner, 66 T.C. 101 (1976). On account of our holding, however, we need not address every such argument respondent raised in this case. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent. 3(...continued) purchaser as “Edith Littlefield Sundby, SBMI Interiors”. Another invoice labeled “office decorative fabric for couch” listed the purchaser only as “SBMI Interiors”, while numerous other invoices for similar items list only petitioner wife as the purchaser. No mention is made of SBMI Interiors elsewhere in the record, and petitioners have not argued that petitioner wife was engaged in a trade or business of any type, other than with respect to the $866 in income that she received from Personalized Workout of La Jolla, Inc.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
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