Laura D. Seidel - Page 11

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               Other expenses:                                                        
                    Show booth expenses                     500                       
                    Bank fees                               120                       
                    Security 6%                             57                        
                    Pest control 6%                          43                       
                         Total expenses                     $1,743                    
                         Net Business Loss                  $5,442                    
               As part of her business expenses, petitioner claimed a truck           
          and automobile expense of $273 on her original return and                   
          increased such expense to $451 on her “amended return”.4                    
          However, no actual log of expenses or mileage was kept as to                
          petitioner’s claimed automobile expense.  Petitioner did keep               
          documents of jewelry shows that she claims she attended and                 
          records of clients’ addresses that petitioner allegedly visited             
          on business matters.  Petitioner did not keep a mileage log for             
          any business trips made in taxable year 1999.  As to her other              
          business expenses, petitioner does not know how these expenses              
          and deductions were calculated.                                             
               Petitioner was disabled and unable to work from February to            
          June 1999.  While on disability, petitioner spent no time on her            
          jewelry activity, the Port of Mystery.  During taxable year 1999,           
          petitioner participated in only two shows to exhibit Port of                
          Mystery jewelry.  The first show was a 3-day show which was held            
          in Sacramento, California; the second was a 2-day show which was            
          held in Marysville, California.                                             


          4Such amended return was not filed with the Internal Revenue                
          Service but was merely exchanged with respondent’s counsel as               
          part of the parties’ informal document exchange.                            




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