Gerry M. Griggs - Page 11

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          Schedule C Losses                                                           
               Petitioner submitted a Schedule C, Profit or Loss From                 
          Business, to respondents’s counsel for four putative businesses.            
          Supporting documents relating to only one of them were provided             
          in response to the Court’s August 4, 2005, order.                           
               On November 1, 2000, petitioner purchased a one-third                  
          interest in a luxury suite at Enron Field/Minute Maid Park for              
          Houston Astros baseball games for $26,000.  The “business”, as              
          described by petitioner, was the resale of the luxury suite                 
          tickets.  Petitioner argues that he is entitled to claim a loss             
          of $17,671.54 from this “business”.                                         
               Petitioner’s evidence that he was carrying on a ticket                 
          resale business is a receipt for purchase or use of the luxury              
          suite, a receipt for catering services in the suite, and one                
          invoice to one person for “2 Nights Enron Box” at $1,008 per                
          night.                                                                      
               Section 162(a) generally allows a deduction for ordinary and           
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.  Generally, no deduction is                
          allowed for personal, living, or family expenses.  See sec. 262.            
          The taxpayer must show that any claimed business expenses were              
          incurred primarily for business rather than social reasons.  See            
          Rule 142(a); Walliser v. Commissioner, 72 T.C. 433, 437 (1979).             
          To show that the expense was not for personal reasons, the                  






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