Lampanh and Sykhane Pchan - Page 4

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          petitioner reported both gross receipts and gross income of                 
          $26,656, car and truck expenses of $17,181, and other expenses of           
          $7,085.                                                                     
               During the examination of the tax returns, petitioner did              
          not present any documentation for the car and truck expenses.               
          Respondent’s examining agent, however, accepted petitioner’s                
          representation that petitioner drove from his place of employment           
          to his Schedule C activity at the rate of 4 miles per day, 6 days           
          a week.  Petitioner was accordingly allowed deductions for car              
          and truck expenses of $455 for 2002, and $449 for 2003, based on            
          the applicable standard mileage rates for those years.                      
               With respect to other expenses deducted on the Schedules C,            
          the only evidence presented during examination was an earnings              
          statement for the period ending December 15, 2002.  The earnings            
          statement indicated that “receivables” of $1,754.10 and the cost            
          of tools of $118.21 were withheld from petitioner’s paycheck.               
          The examining agent accepted petitioner’s explanation that the              
          withheld amounts represented money that petitioner borrowed from            
          his employer to pay for a computer and tools.  Petitioner was               
          allowed deductions for other expenses of $1,872 for each of 2002            
          and 2003.                                                                   
               Respondent issued to petitioner statutory notices of                   
          deficiency for 2002 and 2003 determining that petitioner failed             



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