Larry D. and Sheryl J. Svoboda - Page 7

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               On December 29, 2000, petitioners subscribed to the program.           
          Petitioners chose promotional service program C and furnished               
          four referrals in the subscription agreement.  Petitioners paid             
          AdaCom $2,500 ($100 in 2000 and $225 per month for 12 months in             
          2001)4 and were credited with $7,750 in promotional services for            
          a subscription to the program for the tax year 2000.                        
               AdaCom issued a Form 1099 to petitioners in the amount of              
          $7,750 for the 2000 tax year.  This amount represented the                  
          alleged bartering income from AdaCom for promotional services and           
          was reported on a Schedule C for “Worldwide Products” for the               
          taxable year 2000.                                                          
               On the basis of their subscription to the program,                     
          petitioners claimed a $5,250 business expense deduction and a               
          $5,000 section 44 credit on their income tax return for 2000.               
          Petitioners carried over a portion of the section 44 credit to              
          2001.  The deficiency for the taxable year 2001 results from a              
          carryover of the section 44 credit from the taxable year 2000.              
          Respondent determined a deficiency in petitioners’ Federal income           
          tax for 2001 in the amount of $2,474 as a result of the                     
          disallowance of petitioners’ claimed carryover of the section 44            
          credit.                                                                     



               4  The total payments made by petitioners and stipulated by            
          the parties equal $2,800.  The parties fail to explain the                  
          discrepancies contained in the stipulation of facts.                        





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