Desta Taye-Channell and Bruce C. Channell - Page 7

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          four referrals in the subscription agreement.  Although                     
          promotional service program C required petitioners to display and           
          distribute AdaCom brochures and display an AdaCom window decal,             
          petitioner Bruce Channell testified that he did not remember                
          whether he displayed an AdaCom window decal and that AdaCom did             
          not check to see whether he had displayed a window decal or                 
          distributed brochures.                                                      
               Petitioners paid AdaCom $2,500 and were credited with $7,750           
          in promotional services for a subscription to the program for the           
          tax year 2000.                                                              
               AdaCom issued a Form 1099 to petitioners in the amount of              
          $7,750 for the 2000 tax year.  This amount represented the                  
          alleged bartering income from AdaCom for promotional services and           
          was reported on petitioners’ Schedule C for the taxable year                
          2000.  This was the only income reported on petitioners’ Schedule           
          C.                                                                          
               Based on their subscription to the program, petitioners                
          claimed a $5,250 business expense deduction and a $5,000 section            
          44 credit on their income tax return for 2000.                              
               Respondent determined a deficiency in petitioners’ Federal             
          income tax for 2000 in the amount of $1,935.  Respondent issued a           
          notice of deficiency which stated:                                          
               We adjusted your Schedule C, Gross Receipts, and Other                 
               Expenses.  The adjustments are to decrease income by                   
               monies recorded as received from bartering in the                      
               amount of $7,750.00, to disallow the advertising                       





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