David E. Christensen - Page 3

                                        - 3 -                                         
          income tax returns until October 28, 2002.  On February 2, 2003,            
          respondent prepared a substitute for return for 1997.  On July              
          12, 2004, respondent issued notices of deficiency to petitioner             
          for the years at issue.                                                     
               Respondent determined petitioner received taxable income in            
          1997 based upon the Internal Revenue Service administrative                 
          record of petitioner’s 1997 third-party payor information                   
          (Administrative Record).  Based upon the Administrative Record,             
          petitioner received:  (1) W-2, Wage and Tax Statement, income of            
          $69,990, consisting of (a) $22,438 from Auspex Systems, Inc.; (b)           
          $33,269 from Microcadam, Inc.; and (c) $14,283 from NPC Admin.              
          Services DCP (NPC); (2) 1099-INT, Interest Income, income of                
          $120, consisting of (a) $13 from Capital One FSB; (b) $18 from              
          Glendale Federal Bank; and (c) $71 from Pasadena Federal Credit             
          Union; and (3) 1099-R, Distributions from Pensions, Annuities,              
          Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts,              
          etc., income of $8,399 from the Public Employees’ Retirement                
          System, for the State of California.                                        
               Respondent disallowed petitioner’s Schedule C expenses of              
          $46,669, $44,451, $44,063, and $39,135 for 1998, 1999, 2000, and            
          2001, respectively, for lack of substantiation.  The disallowance           
          of Schedule C expenses caused petitioner’s adjusted gross income            
          to increase.  As a result, petitioner’s Schedule A, Itemized                
          Deductions, deductions were reduced by $873, $864, and $764 in              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011