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percent of Raphael Nwankwo’s income when he returned to Nigeria.
Raphael Nwankwo died in August 2002.
Caroline Nwankwo resided with petitioners throughout 2002.
In early 2003, she left petitioners’ home to live with distant
relatives near Baltimore, Maryland.
For each of the taxable years 2002 and 2003, petitioners
included with their Federal income tax return a Schedule C,
Profit or Loss From Business, related to Mr. Nwankwo’s trucking
business.
Taxable Year 2002
The income and expenses of Mr. Nwankwo’s trucking business
for taxable year 2002 were reported as follows:
Income $61,723
Expenses:
Commissions & fees 3,001
Depreciation 1,775
Employee benefit programs 1,241
Insurance 4,100
Legal & professional 2,850
Repairs & maintenance 11,210
Taxes & licenses 2,906
Travel 3,202
Other expenses*2 20,785
Profit 10,653
*Consisted of:
Tolls and parking 5,115
Uniforms and cleaning 2,713
2Respondent disallowed deductions for Mr. Nwankwo’s
uniforms, dry cleaning, and telephone expenses. (Of these
expenses, respondent allowed petitioners’ fuel costs, which were,
notably, identical to the amount claimed in taxable year 2003.)
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Last modified: May 25, 2011