- 2 -
should not be cited as authority.
Respondent determined deficiencies in petitioner’s Federal
income taxes of $8,924 and $10,084 for 1998 and 1999,
respectively.
After concessions,2 the issues for decision are: (1)
Whether the statute of limitations bars the assessment of the
deficiencies for 1998 and 1999; if the statute of limitations is
not a bar, (2) whether petitioner is entitled to dependency
exemption deductions for his parents in 1998 and 1999; (3)
2 Petitioner concedes: (1) For 1998, he is not entitled to
deduct a dependency exemption for his sister, Christina Szasz;
(2) for 1999, he received unreported income in the aggregate
amount of $5,512; and (3) he is not entitled to the following
Schedule C, Profit or Loss From Business, deductions (to the
limited extent provided herein) that were disallowed by
respondent:
Expense 1998 1999
Advertising $384 $312
Depreciation 5,057 1,980
Mortgage interest -0- 796
Other interest -0- 1,000
Legal and professional services78 94
Office expense 235 258
Rent 664 3,577
Repairs and maintenance -0- 191
Supplies 261 283
Taxes and licenses 1,195 697
Travel, meals, and entertainment-0- 185
Other expenses--telephone 75 78
Other expenses--points -0- 675
Respondent concedes: (1) For 1998 and 1999, petitioner is
entitled to deduct car and truck expenses in the amounts of
$6,763 and $6,876, respectively, as claimed on petitioner’s
Schedules C; and (2) for 1999, petitioner is entitled to deduct
mortgage interest of $4,855, taxes and licenses of $931, and
points of $417 as Schedule A, Itemized Deductions, expenses,
rather than as Schedule C expenses as claimed and disallowed in
the notice of deficiency.
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