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IV, Information on Your Vehicle, petitioner did not complete the
section and indicated “SEE STMT”. Petitioner attached a Schedule
C “Multiple Auto Statement”. Under the heading “Vehicle 1”,
petitioner listed business miles of 14,200. Under the heading
“Vehicle 2”, petitioner listed business miles of 4,000.
For 2000, petitioner claimed a Schedule C interest deduction
on a loan he entered into with his mother, Rhoda Colvin, in the
amount of $5,195. Respondent disallowed the entire deduction.
Petitioner presented as substantiation a photocopy of the front
of a check issued to his mother in the amount of $5,000. A
handwritten notation on the memo line of the check indicated that
the check was for “Loan Repayment”. Other handwritten notations
on the top of the check were “Loan Pay & Int 4575”, “Mar Mtg
425.00”, and “also Honda Ref $300 toward GLC Loan of $35,000”.
Petitioner also claimed as a Schedule C deduction $1,750 in
fees he allegedly paid to his mother for accounting services, tax
preparation, and representation. Petitioner’s 1997, 2000, and
2003, Federal tax returns indicate that they were prepared by his
mother. Petitioner presented as substantiation an invoice in the
amount of $500 from Colvin Business Services, a business
conducted by petitioner’s mother, to Colvin Business Services II,
petitioner’s business. The invoice, dated April 30, 2000,
reflects that petitioner paid the invoice with check No. 6718 on
June 5, 2000. Petitioner’s original bank statements were
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