Victor Woods - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Bloomingdale, Illinois.                     
               Petitioner is a self-employed motivational speaker.                    
          Petitioner filed his Federal tax return for 1999, reporting                 
          $16,020 in gross receipts and claiming the following deductions             
          on Schedule C, Profit or Loss From Business:                                
                    Expense                                 Amount                    
                    Car and truck expenses                  $5,781                    
                    Insurance (other than health)           984                       
                    Legal and professional services         1,000                     
                    Office expense                          250                       
                    Rent or lease                                                     
                    a. Vehicles, machinery, and equipment    900                      
                    b. Other business property              1,524                     
                    Other expenses                                                    
                    a. Telephone                            1,500                     
                    b. Business supplies                    1,500                     
                    c. Credit card payments                 1,200                     
                    d. Cellular telephone                    1,250                    
                         Total                              15,889                    
               On May 14, 2002, respondent issued a notice of deficiency to           
          petitioner for 1999 determining an income tax deficiency of                 
          $3,438 after denying petitioner’s claimed deduction for Schedule            
          C expenses.  On August 12, 2002, petitioner timely filed a                  
          petition with the Court disputing respondent’s determination.               









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