Marcus V. and Polly A. Booker - Page 11

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          lack of clear, convincing testimony and written substantiation,             
          respondent is sustained on this issue, and the entire $13,405               
          claimed as a deduction for charitable contributions on                      
          petitioners’ 2000 Federal tax return is disallowed.                         
               The third issue relates to Mr. Booker’s trade or business as           
          a tax return preparer and consultant.  Mr. Booker did not                   
          maintain an office, he merely visited his clients at their                  
          business locations.  He referred to his activity as a traveling             
          tax service.  On Schedules C, Profit or Loss From Trade or                  
          Business, of petitioners’ income tax returns for 1999 and 2000,             
          petitioners reported the following income and expenses from this            
          activity:                                                                   

                                             1999                2000                 
          Gross income                       $23,171        $20,118                   
          Expenses                                                                    
               Car and truck                 13,515         12,651                    
               Commissions and fees          419                 629                  
               Office expenses               3,338          3,505                     
               Rent                          891            1,010                     
               Supplies                      14,900         15,198                    
               Taxes/licenses                360                 360                  
               Travel                        -0-                 890                  
               Meals and entertainment       -0-                 611                  
               Utilities                     -0-                 808                  
               Wages                         13,300         14,215                    
               Other expenses                 -0-              420                    
          Total expenses                     $46,723        $50,297                   
          Net loss                 $23,522                  $30,179                   

               In the notices of deficiency, respondent disallowed                    
          deductions for the following expenses:                                      





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