-5- II. Disallowed Deductions and Other Amounts Claimed by Petitioners A. Interest On Schedule E of their 2002 return, petitioners deducted $10,045 in interest. Neither petitioner paid any interest to PCI. B. Labor Expenses On Schedules E of their 2002 and 2003 returns, petitioners deducted $16,757 and $24,171, respectively, of labor expenses. Respondent concedes that petitioners paid $3,122.52 in labor expenses for 2003 (attributable to services performed by William Ray). C. Western Timber Farms, Inc. On each of their 2002 and 2003 returns, petitioners claimed a Schedule E loss relating to an entity known as Western Timber Farms, Inc. D. Orion: Cost of Goods Sold/Capital Loss On Schedule C, Profit or Loss From Business, of their 2002 return, petitioners claimed $40,000 in cost of goods sold related to Orion Venture (Orion). The “Principal business or professional activity code” entered on the Schedule C for Orion is 523900, which the Schedule C instructions state is for “Other financial investment activities (including investment advice)”. On their 2002 and 2003 returns, petitioners indicated that they did not have an interest in a financial account in a foreignPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007