- 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