William S. Fairey, Jr., and Susan R. Fairey - Page 8

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               On their 2000 tax return, petitioners deducted $16,500                 
          (which they never paid) for legal expenses twice:  As a                     
          Schedule C legal or professional expense; and as a miscellaneous            
          itemized deduction for attorney’s fees.                                     
               Petitioners deducted loan repayments of $27,000 to Davoli              
          and $27,000 to Pekas in 2000 as legal and professional expenses             
          on the Schedule C for petitioner’s consulting activity.                     
               Petitioners deducted the $2,535 cost of a computer on their            
          2000 income tax return twice:  As a depreciation expense; and as            
          an office expense.                                                          
          D.   Respondent’s Examination and Determination                             
               1.   Examination of Petitioners’ 1999 Tax Return                       
               On July 13, 2001, respondent’s revenue agent Joan                      
          Hughs (Hughs) sent a letter to petitioners in which she invited             
          them to a conference as part of the audit of their 1999 income              
          tax return and requested copies of all Forms W-2 they had                   
          received, records of the Schedule C gross receipts, a brief                 
          history of the Schedule C business, statements from their                   
          employers of their reimbursement policies, records of all of                
          their employee business expenses, legal and professional                    
          expenses, office expenses, supplies expenses, other expenses,               
          repair receipts, appointment books, and records of travel, meal,            
          and entertainment expenses.                                                 







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