- 13 - Before the trial in this case commenced, petitioner again produced for review by respondent’s employees, including a revenue agent and an Appeals officer, voluminous records in support of the Schedule C deductions claimed on her returns for the years at issue. Respondent’s review of petitioner’s records resulted in the preparation of itemized lists of some of petitioner’s canceled checks, credit card expenditures, and receipts. The lists were revised on several occasions and admitted into evidence during trial. The lists were prepared without any reference to the categorization of expenses claimed on petitioner’s Schedules C for the years at issue because respondent claimed that he could not tell how petitioner’s expenses were grouped for reporting purposes on petitioner’s returns. At the beginning of trial, respondent conceded that petitioner had deductible Schedule C expenses for the years at issue in the following amounts: Year Amount Exhibit No. 1987 1$50,184.70 38-R 1988 64,442.41 39-R 1989 77,162.01 40-R 1990 73,632.74 41-R 1Respondent used a subtotal ($11,144.18) instead of the total ($12,034.71) from Sec. B of Ex. 38-R in calculating the amount of Schedule C expenses he conceded for 1987 ($49,294.17). Following trial, respondent conceded additional Schedule C deductions for each of the years at issue as follows:Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011