Marcus V. and Polly A. Booker - Page 12

                                       - 11 -                                         
                                             1999                2000                 
          Car and truck                      $13,515        $12,651                   
               Commissions and fees          -0-            629                       
               Office expenses               -0-            3,505                     
               Rent                          -0-            1,010                     
               Supplies                      14,900         15,198                    
               Taxes/licenses                -0-            360                       
               Utilities                     -0-            808                       
               Wages                          13,300           14,215                 
          Total adjustments            $41,715              $48,376                   

               Section 162 allows a deduction for ordinary and necessary              
          expenses that are paid or incurred during the taxable year in               
          carrying on a trade or business.  Sec. 162(a); Deputy v. duPont,            
          308 U.S. 488, 495 (1940).  Taxpayers carrying supplies on hand              
          can deduct the costs of those supplies in the amount that they              
          are actually consumed and used in operation during the taxable              
          year for which the return is made, if the cost of the supplies              
          was not deducted for any previous year.  If the supplies are                
          incidental and are carried on hand with no record of consumption            
          kept, the taxpayer may deduct the total cost of such supplies               
          purchased during the taxable year for which the return is made.             
          Sec. 1.162-3, Income Tax Regs.                                              
               At trial, respondent conceded the following disallowed                 
          expenses:                                                                   













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