- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011