Conrad Fitzgerald Lewis - Page 19

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          Therefore, we sustain respondent’s determination as to the                  
          taxable year 2000.                                                          
               B.  Taxable Year 2001                                                  
               As previously stated, on his Schedule C for taxable year               
          2001 petitioner reported $5,000 of business income from the                 
          business.  Additionally, petitioner deducted $25,440 in business            
          expenses, which resulted in a reported business loss of $20,440.            
          Respondent, in the notice of deficiency, disallowed the entire              
          amount of petitioner’s claimed $25,440 Schedule C business                  
          expense deductions for taxable year 2001.                                   
               On the basis of the record in this case, for the taxable               
          year 2001 petitioner has substantiated through the aforementioned           
          documents business expenses in the following amounts:                       
               1.   Rent                          $8,340.00                           
               2.   BellSouth phone expenses      $1,483.96                           
               3.   SSE&G utility expenses       $1,044.81                            
                                   Total  $10,868.77                                  
          Petitioner has substantiated Schedule C business expenses for               
          taxable year 2001 of $10,869.  We conclude that petitioner is               
          entitled to deduct Schedule C business expenses for taxable year            
          2001 of $10,869.                                                            
               C.  Taxable Year 2002                                                  
               As previously stated, on his Schedule C for taxable year               
          2002 petitioner reported $1,352 of business income from the                 
          business.  Additionally, petitioner deducted $8,631 in business             
          expenses, which resulted in a reported business loss of $7,279.             





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