- 14 - The Court accordingly finds that petitioners failed to substantiate any of the expenses in connection with either the Keepsake or Amway activity. The deductions claimed with respect to these activities, for both years, are disallowed to the extent they exceed the income reported for the activities on petitioners’ Schedules C. Although the record is not entirely clear as to the extent petitioners operated their activities and generated expenses, in the notice of deficiency, respondent did not determine that the reported gross receipts for the 2 years were false or fictitious. Respondent only determined that the expenses claimed in excess of the gross income were false, fictitious, and fraudulent. In fact, respondent allowed deductions for business expenses for Keepsake and Amway to the extent of the reported gross receipts, $18,553.91 and $7,285.75 for 1994 and 1995, respectively. As respondent does not challenge whether petitioners received income from either activity, it follows that petitioners generated some expenses in the operation of both Keepsake and Amway. Therefore, respondent’s determination is sustained and petitioners are not entitled to any of the Schedule C losses for either Keepsake or Amway for tax years 1994 and 1995.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011