-5- 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008