John A. Walz, Jr. - Page 7

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          petitioner reported his profession as “INDEPENDENT PROFESSIONAL             
          MUSICIAN/SOLOIST CELLIST-Classic Music.”  His reporting Code was            
          listed as 711510 (Independent artists, writers, & performers).              
          For 2000, petitioner reported $174,367 of income on his Schedule            
          C.                                                                          
               Petitioner claimed deductions on the Schedule C for the                
          following expenses, which total $83,588:                                    
             Auto                              $ 5,907                                
          Depreciation                       12,161                                   
          Insurance                           2,632                                   
          Interest                              350                                   
          Legal/professional                  1,000                                   
          Office                              1,874                                   
          Rent                                6,869                                   
          Repairs                             3,741                                   
          Supplies                            2,707                                   
          Travel                             10,135                                   
          Meals                               1,969                                   
          Utilities                           5,014                                   
          Other                              20,687                                   
          Home office                         8,542                                   
               Respondent issued a notice of deficiency on August 11, 2003.           
          Respondent disallowed the Schedule C expenses and made                      
          computational and other adjustments.                                        
               After the notice of deficiency was issued, petitioner filed            
          a Form 1040X, Amended U.S. Individual Income Tax Return, for 2000           
          on September 14, 2004.  On that form, petitioner stated that he             
          was “Changing from originally filed Schedule C with Form 1040, to           
          using Form 2106 (Employee Business Expense)”.  In his amended               
          return, petitioner substantially reduced his claimed business               
          expenses.                                                                   





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