Larry T. Cooper - Page 5

                                        - 4 -                                         
               Car and truck expenses                  $5,231                         
               Depreciation and section 179 expense    1,268                          
               Office expense                          68                             
               Repairs and maintenance                 1,529                          
               Travel                                  518                            
               Meals and entertainment                 101                            
               Entry fees                              2,261                          
               Feed/hay                                913                            
               Vet/meds                                2,513                          
               Tack maintenance                        2,053                          
               Farrier                                  1,206                         
                                                       17,661                         
               Petitioner failed to timely file a Federal income tax return           
          for 2001.  Respondent prepared a substitute for return (SFR) for            
          2001.  Respondent determined a deficiency in petitioner’s Federal           
          income tax and that petitioner is liable for additions to tax.              
          Petitioner had not yet filed a Federal income tax return for 2001           
          when the notice of deficiency was issued.  Respondent had also              
          prepared SFRs for petitioner for 1999 and 2000. Respondent, in              
          preparing SFRs for petitioner, treated him as a single taxpayer.            
               On January 7, 2005, petitioner faxed to respondent an                  
          unsigned joint Form 1040, U.S. Individual Income Tax Return, for            
          2001.4  Attached to the return were various schedules including:            
          (1) Schedule A, Itemized Deductions; (2) Schedule B, Interest and           
          Ordinary Dividends; and (3) two Schedules C, Profit or Loss From            
          Business.  Respondent accepted all the items on the return except           
          for the ordinary loss of $15,920 claimed in connection with Mrs.            


               4The parties agree that petitioner should be treated as                
          filing a joint return with his wife for 2001.                               





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Last modified: May 25, 2011