William S. Fairey, Jr., and Susan R. Fairey - Page 16

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               Petitioners contend that, for 2000, they may deduct $16,500            
          for legal fees paid by TruGreen to Nelson Hesse, $54,000 for loan           
          repayments to Davoli and Pekas, $250 to Richard Weldon, and                 
          $221.45 to an unidentified person.  We disagree.  Petitioners may           
          not deduct as a business expense TruGreen’s payment of $16,500 to           
          Nelson Hesse or $54,000 of loans repaid to Davoli and Pekas.                
               Petitioners did not show that they paid the $250 or the                
          $221.45 or that those amounts were business expenses.  We                   
          conclude that petitioners may not deduct any amounts for legal              
          and professional expenses for the years in issue.                           
               3.   Supplies Expenses                                                 
               Petitioners claimed deductions for supplies expenses of                
          $2,856 for 1999, $4,962 for 2000, and $729 for 2001 on the                  
          Schedules C for petitioner’s consulting activity.  Petitioners              
          contend that he paid $2,535 in 1999 to buy a computer.                      
          Petitioner was billed $2,535 for that computer.  However, there             
          is no evidence than petitioners paid that amount or to what                 
          extent he used it for his consulting activity.                              
               Respondent conceded that petitioners may deduct $92.49 in              
          1999 for a subscription to Media Week magazine.                             
          Petitioners offered no evidence substantiating their                        
          deductions for supplies for 2000 or 2001.  We conclude that                 
          petitioners may not deduct more for supplies expenses than                  
          respondent allowed.                                                         






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