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consider some of the other expenses. Petitioner testified that
the $1,953 bad debt expense claimed related to interest paid on
personal debt that he incurred while out of work. It is clear
that such interest expense would not be deductible. Sec. 163(h).
Petitioner testified that the claimed insurance expense related
to his privately owned automobile. Petitioner did not establish
that any deductions relating to the use of his privately owned
automobile are deductible. Petitioner also claimed a deduction
for business use of his home. Petitioner provided some minimal
information as to activities that took place in a room in his
house, but he did not establish that these expenditures
constitute an ordinary and necessary expense in relationship to
his activity as a pipefitter. Petitioner did not present any
documents or explanations as to other expense deductions claimed.
Based on the above analysis petitioner is not entitled to any of
the deductions claimed on his Schedule C pipefitting.
The claimed deductions on petitioner’s Schedule C trucking
present a different issue. As indicated, respondent has the
burden of proof to establish that the claimed deductions do not
relate to petitioner’s trucking activity and are not properly
deductible as miscellaneous itemized deductions. Respondent
presented no evidence or argument in this regard. Accordingly we
hold for petitioner on this issue.
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