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Respondent determined a deficiency of $2,320 in petitioner’s
Federal income tax for the year 2001. The sole issue for
decision is whether petitioner is entitled to certain deductions
claimed on Schedule C, Profit or Loss From Business, for the year
in question in excess of amounts allowed by respondent.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Indianapolis, Indiana.
Petitioner is an independent contractor and works on a
commission basis as a courier. His sole client is a delivery
service called Pillow Express. Although petitioner was available
to make out-of-State deliveries, his primary work for Pillow
Express was local and in-State deliveries. Petitioner drove one
of the two cars he owned for the majority of the deliveries;
however, petitioner never made out-of-State deliveries using his
own car. If he had to deliver anything outside of Indiana,
petitioner would either rent a car or drive a van owned by Pillow
Express. In addition, when petitioner delivered large items
locally, he would use one of the vans owned by Pillow Express.
Pillow Express did not charge petitioner when he had to use a
company van, but it also did not reimburse petitioner for the
cost of using his own vehicle to make some of the deliveries.
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Last modified: May 25, 2011