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JRC
Rent $45,441
Marketing 41,335
Professional fees 16,008
Auto rental and expenses 20,893
Total 123,677
RSC
Rent $82,252
New York apartment tax 3,121
Lodging 8,419
Professional fees 18,037
Transportation 24,905
Travel 20,929
Marketing 141,707
Management, staff, and 192,500
administration
Interest 36,392
Total 528,262
Respondent asked petitioner to substantiate the deductions
that flowed through from JRC and RSC to his delinquent Form 1040
for 2001. Petitioner did not do so.
Respondent filed an amendment to answer. In it, respondent
asserts that petitioner’s 2001 deficiency and additions to tax
were larger than respondent had determined in the notice of
deficiency on the basis of the amount of income first reported to
respondent in the Form 1040 petitioner had faxed to respondent.
Respondent also asserted in the answer that, although requested
to do so by respondent, petitioner did not provide documents
substantiating any deductions for 2001.
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Last modified: May 25, 2011