Charles A. Brown, Jr. and Linda L. Brown - Page 4

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               Mr. Brown’s Schedule C for 1998 reflected the following:               
          Gross Income                  $1,800                                        
          Less:                                                                       
               Car and truck            2,496                                         
               Insurance                                                              
               (other than health)      3,096                                         
               Rent or lease            6,002                                         
               Utilities                1,800                                         
          The insurance amount includes car, homeowner’s, and life                    
          insurance expenses.  The amounts claimed as a deduction under car           
          and truck and rent or lease are for expenses for a leased 1997              
          Acura.  The amount deducted under utilities relates to expenses             
          from Mr. Brown’s home office.  Petitioners also deducted $7,375             
          in charitable contributions.                                                
               On April 15, 1999, petitioners timely requested an                     
          extension for the filing of their 1998 return.  The filing date             
          was extended to August 15, 1999.  Petitioners’ 1998 return was              
          filed on January 25, 2001.                                                  
               Upon examination, respondent disallowed the following                  
          amounts claimed as deductions on Mr. Brown’s Schedule C:  $2,042            
          of the car and truck expenses; $2,377 of the insurance expenses;            
          $4,530 of the rent or lease expenses; and the entire $1,800 of              
          utilities expenses.  Respondent also disallowed $1,600 of the               
          claimed deduction for charitable contributions.                             











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