James B. Clark - Page 4

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          of the amount he deducted for moving expenses was the cost of               
          replacing the roof on his house in Idaho.                                   
               In May 1999, petitioner organized a corporation named                  
          Totally Awesome Internet Services, Inc. (TAIS, Inc.).  TAIS,                
          Inc., was dissolved in April 2000.  After dissolution, petitioner           
          continued to operate the business as a sole proprietorship.                 
               Petitioner prepared and he and Mrs. Clark timely filed a               
          joint income tax return for 2000.  They reported $16,417 of                 
          income, $13 tax due, and $2,616 tax withheld, and they claimed a            
          $2,603 refund.  On a Schedule C, Profit or Loss from Business,              
          included with that return, they reported $1,682 in gross receipts           
          and sales for TAI and deducted $12,289 in business expenses.                
               Jackson Hewitt Tax Service prepared and electronically                 
          filed a joint income tax return for 2001 for petitioner and Mrs.            
          Clark.  On that return, they reported $42,878 of income, $36,781            
          of itemized deductions, $28 tax due, and $4,551 tax withheld, and           
          they claimed a $4,523 refund.  They deducted $22,131 of                     
          unreimbursed employee expenses petitioner allegedly incurred in             
          2001.                                                                       
          C.   Respondent’s Examination of Petitioner’s Tax Returns for               
               1998, 2000, and 2001                                                   
               Respondent selected petitioner and Mrs. Clark’s 1998 Federal           
          income tax return for examination on August 17, 2001.  Petitioner           
          and Mrs. Clark executed a Consent to Extend the Time to Assess              







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