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estate activity. On Schedule E, they again reported no rental
income from the Morningside Heights dwelling and claimed
deductions of $1,322 for taxes, depreciation, and insurance
expenses, for a net loss from this property of $1,322.
The following is a list of the specific Schedule C expenses
at issue for which petitioners claimed and respondent allowed
deductions in the statutory notice of deficiency.
For 1999:
Claimed Allowed
Deductions On Sch. C On Sch. C
Car and truck expenses $17,446 $1,050
Travel/meals/entertainment 1,500 304
Utilities 1,220 223
For 2000:
Claimed Allowed
Deductions On Sch. C On Sch. C
Car and truck expenses $7,800 1 $ 305
Travel/meals/entertainment 1,500 248
Utilities 1,300 1,300
1 The stipulations incorrectly state that respondent allowed
$395 for this expense for 2000. The record reflects that $7,800
was claimed and $7,495 was disallowed in the explanation of
adjustments, for a difference of $305. The Court is not bound by
a stipulation of fact that appears contrary to the facts
disclosed by the record. Rule 91(e); Estate of Eddy v.
Commissioner, 115 T.C. 135, 137 n.4 (2000); Jasionowski v.
Commissioner, 66 T.C. 312, 318 (1976).
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