- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007