Thomas Edwards - Page 4




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          checks at the banks on which they were drawn.  Petitioner paid              
          workers and paid other expenses in cash.  During 2001, petitioner           
          used an extended-cab pickup truck to transport his crew and                 
          materials to tile jobs.                                                     
               Petitioner did not make any estimated tax payments and did             
          not pay any withholding taxes in 2001.  Petitioner did not file a           
          tax return for either 2000 or 2001.                                         
               Pursuant to section 6020(b), respondent prepared a                     
          substitute for return for 2001.  Respondent included self-                  
          employment income reported on Forms 1099-MISC, Miscellaneous                
          Income, and Social Security benefits reported on Form SSA-1099,             
          Social Security Benefit Statement, on the substitute for return.            
          Respondent allowed a personal exemption and a standard deduction            
          on the substitute for return.2  Respondent issued a notice of               
          deficiency.  Petitioner timely filed a petition for                         
          redetermination.                                                            
                                     Discussion                                       
               The parties have stipulated the items of income but dispute            
          whether petitioner is entitled to deductions for expenses related           
          to his tile business.3  Petitioner did not submit a Schedule C,             

               2 As indicated supra note 1, respondent concedes the filing            
          status and home mortgage interest deduction.                                
               3 Respondent does not dispute that petitioner’s installation           
          of tile in 2001 qualifies as a trade or business for Federal                
          income tax purposes. On the record as a whole, the Court presumes           
                                                             (continued...)           






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