- 5 - Petitioner did not issue Ms. Brownell a Form W-2 in connection with the manufactured home. Petitioner filed a Federal income tax return for taxable year 1998. With this return, he filed a Schedule C, Profit or Loss From Business, for his general contracting business. Petitioner reported cost of goods sold of $470,394. As part of this amount, petitioner included $43,003 for the double-wide manufactured home. Separately, petitioner claimed deductions on the Schedule C for wage expenses of $33,576 and for legal and professional services expenses of $16,149. In the notice of deficiency, respondent determined that the purchase of the manufactured home was a nondeductible personal expense and not properly characterized as a cost of goods sold.2 Respondent also disallowed $6,610 of the claimed deduction for legal expenses because they likewise were determined to be nondeductible personal expenses. The issues in this case are decided on the basis of the record without regard to the burden of proof. See sec. 7491; Rule 142(a). The first issue for decision is whether petitioner is entitled to deduct as a business expense the cost of the 2Petitioner no longer argues that the cost of the manufactured home should be included in the Schedule C cost of goods sold. Rather, in his brief he argues that he is entitled to deduct the cost of the home as a business expense.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011