- 4 - Shirley, Long Island. Petitioner did not lease any of those properties to tenants during 1996-98. Petitioner’s Returns For each year in issue, petitioner filed a Form 1040, U.S. Individual Income Tax Return, showing zero taxable income and no tax due. On a Schedule C attached to each of those returns, petitioner listed as his principal business or profession “research and development” and as the name of his business “A.S.K. Enterprises”. Only the 1999 and 2000 Schedules C listed a business address, which was 30 E. 3d St., Bethlehem, PA 18015 (the Bethlehem property). All of the Schedules C report zero gross receipts and zero gross income, and they report the following amounts of total expenses (and resulting losses): Year Schedule C Expenses 1996 $72,786 1997 75,388 1998 80,675 1999 85,845 2000 80,020 The Notice The notice disallows all of petitioner’s 1996-98 reported Schedule C expenses and a portion ($33,945 for 1999 and $40,113 for 2000) of those expenses for 1999 and 2000. Those disallowances are based upon respondent’s determination that petitioner failed to establish that he “incurred or, if incurred,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011