Carlos H. and Maria C. Gonzalez - Page 6

                                        - 5 -                                         
          petitioner for consultation services.3  As stated in the notice             
          of deficiency, the expenses were disallowed for the reason that             
          “it has not been established that the expenses were incurred and            
          paid”, and, additionally, “it has not been established that the             
          activity described in Schedule C for the taxable years 2000 and             
          2001 constitutes a bona fide trade or business venture entered              
          into for profit.”                                                           
               The purpose of the purported activity, as described by                 
          petitioners, was to sell oil field equipment from the United                
          States to oil and gas exploration companies in Colombia, South              
          America.  Petitioners began reporting this activity on their                
          Federal income tax return for 1994.  They claimed losses from               
          this activity as follows:4                                                  








               3Under sec. 183(b)(2), if an activity is not engaged in for            
          profit, deductions for expenses are allowable only to the extent            
          of the gross income derived from such activity.  Since                      
          petitioners conceded that the $3,000 in income was not related to           
          the activity, none of the expenses is allowable as deductions to            
          the extent of that reported income.                                         
               4The record does not show whether petitioners reported any             
          gain or loss from this activity for the years 1994, 1995, and               
          1996.  In the stipulation, petitioners agreed that their claimed            
          losses for 2000 should be reduced from $41,492 to $32,646, and              
          the 2001 loss should be reduced from $44,225 to $36,240.  With              
          these concessions, the total claimed losses would be $199,110               
          instead of the $215,941 shown above.                                        




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

Last modified: May 25, 2011