Walter Michael Alley - Page 5

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          received payments from Pacific totaling $7,050 for the taxable              
          year 2001.                                                                  
               Petitioner delinquently filed his taxable year 2000 Form               
          1040, U.S. Individual Income Tax Return, on April 19, 2002.2                
          Petitioner timely filed his taxable year 2001 Form 1040 on April            
          15, 2002.                                                                   
               Petitioner attached to his 2000 Federal income tax return a            
          Schedule C.  On his Schedule C for taxable year 2000, petitioner            
          listed as his principal business or profession:  “Truck Lease”.             
          Petitioner reported $3,3753 of business income on his Schedule C            
          for taxable year 2000 and deducted $16,059 in business expenses.            
          This resulted in a reported business loss in the amount of                  
          $12,684.  Petitioner’s Schedule C business expenses were as                 
          follows:                                                                    
               Line 10   Car and truck expenses             $12,757                   
               Line 16b Interest: Other (Auto loan)         230                       
               Line 21   Repairs and maintenance            2,892                     
               Line 23   Taxes and licenses                 45                        
               Line 27   Other expenses                     135                       
               Line 28 Total expenses                       $16,059                   
               Petitioner attached to his 2001 Federal income tax return a            
          Schedule C.  On his Schedule C for taxable year 2001 petitioner             


          2As previously noted, petitioner stipulated that his Form                   
          1040 for taxable year 2000 was filed delinquently and conceded              
          the addition to tax of $654 pursuant to sec. 6651(a).                       
          3This amount represents the payments received by petitioner                 
          from Pacific for the use of his personal vehicle in furtherance             
          of Pacific’s business.                                                      





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