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reviewable by any other court, and this opinion should not be
cited as authority.
Respondent determined a $10,224 deficiency in petitioner’s
2001 Federal income tax. The issues for decision are: (1)
Whether petitioner is entitled to the cost of goods sold and
expense deductions reported on a Schedule C, Profit or Loss From
Business, included with his 2001 Federal income tax return; and
(2) whether petitioner is entitled to a charitable contribution
deduction.
Background
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Yonkers, New York.
At all times relevant petitioner was employed by the New
York Times. Early in 2001, petitioner acquired an interest in a
business that operated what he describes as a “candy store”
located on Myrtle Avenue in Brooklyn, New York (the business
premises). Pursuant to a Search Warrant On Written Affidavit,
issued April 4, 2001, agents from the Federal Bureau of
Investigation searched the business premises and seized “1 roll
of fax tape”, “2 Pokeman notebooks w/numbers written in there”,
“several index cards w/numbers”, “Nextel phone records”, and
“misc. paperwork”. The criminal activity that gave rise to the
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