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respondent’s revenue agent to discuss the examination. At the
meeting, petitioner produced an “Affidavit of Facts of Robert
Kolbeck” summarily declaring, among other things, that his
entries on his 2000 Schedule C were accurate and correct.
Because petitioner did not adequately substantiate his Schedule C
expenses, respondent issued a report proposing to disallow all of
the expenses.
Petitioner appealed respondent’s proposed disallowance of
his Schedule C expenses to respondent’s Appeals Office. An
Appeals conference was scheduled, but petitioner did not attend
the conference or make any effort to reschedule it. On February
5, 2004, respondent issued a notice of deficiency in which he
disallowed all of petitioner’s Schedule C deductions for lack of
substantiation as follows:
Expense Amount disallowed
Cost of sales $33,798
Advertising 3,909
Commissions and fees 15,012
Insurance 4,698
Rent/Lease - veh./mach./equip. 14,819
Rent/Lease - other 3,900
Taxes and licenses 2,914
Cell phone 1,904
Fuel 14,983
Other expenses 429
Repairs/Maintenance 12,012
Total 108,378
3(...continued)
inquiry into “the correctness of any [tax] return.” 26
U.S.C. �7602(a)(1). * * * [Mattatall’s] assertion that
an affidavit is sufficient is unfounded.
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