Michael L. and Ann Burski - Page 6




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          that IDA paid him compensation of $92,166 in 2001 and $85,918 in            
          2002.  Petitioner reported his compensation from IDA as wages,              
          salaries, tips, etc. on line 7 of the returns but claimed                   
          deductions for expenses he incurred in the course of performing             
          services for IDA on Schedules C, Profit or Loss From Business               
          (Sole Proprietorship).  On the Schedules C, petitioner reported             
          no gross receipts and claimed deductions for the following                  
          expenses:                                                                   
               Expense                            2001        2002                    
               Car and truck                    $4,830       $3,362                   
               Depreciation                     518          5,913                    
               Insurance                        527          871                      
               Legal and professional           104          85                       
               Office expenses                  57           75                       
               Repairs and maintenance          1,446        -0-                      
               Supplies                         324          152                      
               Travel                           23,532       4,385                    
               Meals and entertainment          3,103        3,810                    
               Utilities                        785          1,334                    
               Other expenses                   407          785                      

          B.   Notice of Deficiency and Concessions by the Parties                    
               In the notice of deficiency, respondent treated petitioner             
          as an employee of IDA consistent with his reporting the                     
          compensation from IDA as wages, salaries, tips, etc. on the                 
          returns.  Respondent disallowed all deductions petitioner claimed           
          on Schedules C, explaining that deductions for these amount were            
          not allowed because petitioner had not established that he                  
          incurred, or if he incurred, paid these amounts for ordinary and            






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